Task 1.1, Deliverable 1.1.2 2016 Air Quality Report for ...Environmental Protection Agency (EPA)....

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PGA 582-16-60851-01, Amendment 2 Task 1.1, Deliverable 1.1.2 2016 Air Quality Report for the Austin-Round Rock Metropolitan Statistical Area Prepared by the Capital Area Council of Governments August 23, 2017 PREPARED UNDER A GRANT FROM THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY The preparation of this report was financed through grants from the state of Texas through the Texas Commission on Environmental Quality. The content, findings, opinions, and conclusions are the work of the author(s) and do not necessarily represent findings, opinions, or conclusions of the TCEQ.

Transcript of Task 1.1, Deliverable 1.1.2 2016 Air Quality Report for ...Environmental Protection Agency (EPA)....

Page 1: Task 1.1, Deliverable 1.1.2 2016 Air Quality Report for ...Environmental Protection Agency (EPA). This report serves as the region’s annual “check-in” with EPA as part of the

PGA 582-16-60851-01, Amendment 2 Task 1.1, Deliverable 1.1.2

2016 Air Quality Report for the Austin-Round Rock Metropolitan Statistical Area

Prepared by the Capital Area Council of Governments

August 23, 2017

PREPARED UNDER A GRANT FROM THE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

The preparation of this report was financed through grants from the state of Texas through the Texas

Commission on Environmental Quality. The content, findings, opinions, and conclusions are the work of

the author(s) and do not necessarily represent findings, opinions, or conclusions of the TCEQ.

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2016 Air Quality Report for the Austin-Round Rock Metropolitan Statistical Area

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Executive Summary This is the annual air quality report for the Austin-Round Rock Metropolitan Statistical Area (MSA)

prepared by the Capital Area Council of Governments (CAPCOG) for the members of the Central Texas

Clean Air Coalition (CAC), the Texas Commission on Environmental Quality (TCEQ), and the U.S.

Environmental Protection Agency (EPA). This report serves as the region’s annual “check-in” with EPA as

part of the Clean Air Coalition’s participation in the Ozone Advance Program (OAP) and also serves as a

deliverable to TCEQ under our 2016-2017 air quality planning grant. The report covers January 1, 2016,

through December 31, 2016. Under the most recent MSA definitions promulgated by the Office of

Management and Budget (OMB) in 2015, the Austin-Round Rock MSA consists of Bastrop, Caldwell,

Hays, Travis, and Williamson Counties.

The report is intended to do the following:

Provide an update on the status of air quality in the Austin-Round Rock MSA through 2016

(Section 1);

Provide an update on the latest understanding of the contribution of the region’s emissions to

high ozone levels when they occur (Section 2);

The status of emission reduction measures implemented in the region in 2016 (Section 3);

Ongoing planning activities in the region (Section 4); and

Planning for the future (Section 5).

Except for the following organizations, all Clean Air Coalition members provided a report on 2016

activities to CAPCOG:

Capital Metropolitan Transit Authority (CapMetro)

City of Bastrop

City of Luling

City of Taylor

Texas Nursery and Landscaping Association

Williamson County

CAPCOG will provide an update version of this report to EPA and TCEQ if these organizations provide

reports after this report has been submitted. A supplemental Excel spreadsheet provides details of each

organization’s reported activities.

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Table of Contents Executive Summary ................................................................................................................................. 2 List of Acronyms ...................................................................................................................................... 6 1 Air Quality Status ............................................................................................................................. 8

1.1 Compliance with the NAAQS .................................................................................................... 9 1.2 Maximum Daily 8-Hour Ozone Averages in the Region ........................................................... 12 1.3 Daily Pollution Levels Compared to EPA’s AQI ........................................................................ 16

1.3.1 High Ozone AQI Days ...................................................................................................... 18 1.3.2 High PM2.5 AQI Days........................................................................................................ 18 1.3.3 Distribution of Moderate or Worse AQI Days by Month .................................................. 19

1.4 Seasonal Ozone Exposure ....................................................................................................... 20 1.5 Air Quality Forecasting ........................................................................................................... 21

1.5.1 Ozone Action Days.......................................................................................................... 21 1.5.2 Daily Air Quality Forecasts .............................................................................................. 23

2 Regional Ozone-Forming Emissions ................................................................................................ 24 2.1 Impact of NOX Emissions v. VOC Emissions on Ozone Concentrations ..................................... 24 2.2 2016 Regional Ozone Season Weekday NOX Emissions Profile ................................................ 26

2.2.1 NOX Emissions by Source Type by County ....................................................................... 26 2.2.2 On-Road Sector .............................................................................................................. 27 2.2.3 Non-Road Sources .......................................................................................................... 27 2.2.4 Point Sources ................................................................................................................. 28 2.2.5 Area Sources .................................................................................................................. 30

3 Implementation of Ozone Advance Program Action Plan and Other Measures............................... 31 3.1 Regional and State-Supported Measures ................................................................................ 31

3.1.1 Vehicle Emissions Inspection and Maintenance Program ................................................ 31 3.1.2 Drive a Clean Machine Program ...................................................................................... 35 3.1.3 Texas Emission Reduction Plan Grants ............................................................................ 37 3.1.4 Commute Solutions Program .......................................................................................... 39 3.1.5 Clean Air Partners Program ............................................................................................ 40 3.1.6 Outreach and Education Measures ................................................................................. 41 3.1.7 Property-Assessed Clean Energy (PACE) Program ........................................................... 42 3.1.8 CAPCOG Regional Air Quality Grants ............................................................................... 44

3.2 Organization-Specific Measures and Updates ......................................................................... 44 3.2.1 Texas Lehigh Cement Company ...................................................................................... 44 3.2.2 Austin Energy ................................................................................................................. 47 3.2.3 Commuter Programs ...................................................................................................... 48 3.2.4 Development Measures.................................................................................................. 48 3.2.5 Energy and Resource Conservation ................................................................................. 48 3.2.6 Fleet and Fuel Efficiency Measures ................................................................................. 49 3.2.7 Outreach and Awareness ................................................................................................ 49 3.2.8 Regulation and Enforcement .......................................................................................... 49 3.2.9 Sustainable Procurement and Design.............................................................................. 50

4 Ongoing Planning Activities ............................................................................................................ 50 4.1 Clean Air Coalition Meetings .................................................................................................. 50 4.2 CLEAN AIR Force Meetings ..................................................................................................... 52 4.3 Regional Air Quality Technical Research Activities .................................................................. 52 4.4 Statewide Collaborative Initiatives ......................................................................................... 52

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4.4.1 Regional Air Quality Planning Group ............................................................................... 53 4.4.2 Texas Clean Air Working Group ...................................................................................... 53

5 Planning for the Future .................................................................................................................. 53 5.1 Implications of Veto of Regional Air Quality Planning Funding ................................................ 53 5.2 Implications of Veto of Drive a Clean Machine and Local Initiative Project Funding ................ 54 5.3 Texas Emission Reduction Plan ............................................................................................... 54 5.4 Commute Solutions Program.................................................................................................. 61 5.5 Postponement of Area Designations for 2015 Ozone NAAQS.................................................. 61 5.6 Updates to the Region’s Advance Program Action Plan .......................................................... 62

6 Conclusion ..................................................................................................................................... 62 Table 1-1. Summary of Criteria Pollutant Measurement Periods at Federal Reference Method (FRM)

Monitors in the Austin-Round Rock MSA, 2014-2016 ............................................................................. 10

Table 1-2. Austin-Round Rock MSA Criteria Pollutant Design Values Compared to Primary NAAQS ........ 10

Table 1-3. Fourth-highest MDA8 Measurements at All Ozone Monitoring Stations in the CAPCOG Region,

2014-2016 (ppb) .................................................................................................................................... 13

Table 1-4. Summary of AQI for NO2, O3, and PM2.5 .............................................................................. 16

Table 1-5. OAD Dates and Dates when O3 Exceeded Level of NAAQS, 2014-2016 ................................... 22

Table 2-1. Average 2017 Ozone Concentration Contribution per TPD of NOX Emissions ......................... 26

Table 2-2. 2016 Ozone Season Weekday NOX Emissions by Source Type and County ............................. 27

Table 2-3. 2016 Austin-Round Rock Ozone Season Weekday NOX Emissions by Source Use Type ........... 27

Table 2-4. 2016 Ozone Season Weekday Non-Road NOX Emissions by County (tpd) ............................... 28

Table 2-5. 2015/2016 Ozone Season Weekday Point Source NOX Emissions by County (tpd) .................. 28

Table 2-6. 2015 Ozone Season Day Point Source Emissions in the Austin-Round Rock MSA ................... 28

Table 2-7. 2016 Austin-Round Rock MSA Electric Generating Unit Ozone Season Day NOX Emissions by

Facility ................................................................................................................................................... 30

Table 2-8. 2017 Area Source NOX Emissions by County and Type (tpd) ................................................... 30

Table 3-1. Estimated 2016 NOX and VOC Emission Reductions from I/M Program for Light-Duty Vehicles

(tpd) ...................................................................................................................................................... 32

Table 3-2. I-M Program Statistics for 2016 ............................................................................................. 33

Table 3-3. DACM Program Data for State FY 2016 .................................................................................. 36

Table 3-4. TERP Grants Awarded in the Austin Area in 2016 .................................................................. 38

Table 3-5. MyCommuteSolutions.com Data for 2016 ............................................................................. 39

Table 3-6. Days Texas Lehigh Highlighted on its 2016 Report ................................................................. 45

Table 3-7. Jurisdictions Implementing Idling Restrictions in the Austin-Round Rock MSA ....................... 50

Table 5-1. Changes in TERP "Use of Fund" Restrictions for FY 2018-2019 ............................................... 55

Table 5-2. Alternative Allocation Scenarios for FY 2018-2019 TERP Funding ........................................... 57

Table 5-3. TERP Grant Demand Summary as of April 21, 2017................................................................ 59

Figure 1-1. 2016 Air Quality Monitors in the Austin-Round Rock MSA and Nearby Counties .................... 9

Figure 1-2. Austin-Round Rock MSA Design Values as a percentage of NAAQS ....................................... 11

Figure 1-3. Austin-Round Rock MSA 8-Hour Ozone Design Value 1999-2016 .......................................... 12

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Figure 1-4. Map of CAMS 1605 and vicinity ............................................................................................ 14

Figure 1-5. Map of locations of sampling equipment at CAMS 6602, 2011-2016 .................................... 15

Figure 1-6. Close-up aerial photography of the location of CAMS 6602 sampling equipment in October

2014 ...................................................................................................................................................... 16

Figure 1-7. Number of "Moderate" or ”Unhealthy for Sensitive Groups” Air Pollution Days in the CAPCOG

Region in 2016 by Pollutant ................................................................................................................... 17

Figure 1-8. Number of Days when Ozone Pollution was "Moderate" or Worse by Monitoring Station and

County, 2016 ......................................................................................................................................... 18

Figure 1-9. Number of Days when PM2.5 Pollution was "Moderate" or Worse by Monitoring Station and

County, 2016 ......................................................................................................................................... 19

Figure 1-10. Number of Days when Air Pollution was "Moderate" or Worse in the CAPCOG Region by

Month, 2016 ......................................................................................................................................... 20

Figure 1-11. Weighted Seasonal Ozone Exposure by Monitoring Station and 3-month period, 2016

(W126 ppm-hrs) .................................................................................................................................... 21

Figure 1-12. Ozone Action Day Forecast Accuracy and Success, 2014-2016 ............................................ 23

Figure 1-13. Accuracy and Success of AQI Forecasts for 2016 ................................................................. 24

Figure 2-1. Modeled Impact of Anthropogenic NOX and VOC Emissions from the Austin-Round Rock MSA

on High O3 Days ..................................................................................................................................... 25

Figure 2-2. 2016 Ozone Season Weekday NOX Emissions for the Austin-Round Rock MSA (tpd) ............. 26

Figure 3-1. Trend in Emissions Inspections Compared to Population in Travis and Williamson Counties

2006-2016 ............................................................................................................................................. 34

Figure 3-2. Initial Emissions Inspection Failure Rate Trend 2006-2016.................................................... 34

Figure 3-3. Failure Rate by Model Year .................................................................................................. 35

Figure 3-4. DACM Repair and Replacement Voucher Trends 2009-2016................................................. 37

Figure 3-5. Emission Reductions from TERP Grants Active as of 8/31/2016, 2016-2019.......................... 39

Figure 3-6. Texas Lehigh NOX Emissions by Hour on NOX Reduction Days and Regular Days, 2016 .......... 47

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List of Acronyms AACOG: Alamo Area Council of Governments

AFFP: Alternative Fueling Facilities Program

AQI: Air Quality Index

CAC: Clean Air Coalition

CACAC: Clean Air Coalition Advisory Committee

CAMPO: Capital Area Metropolitan Planning Organization

CAPCOG: Capital Area Council of Governments

CapMetro: Capital Metropolitan Transit Authority

CAMS: Continuous Air Monitoring Station

CAPP: Clean Air Partners Program

CO: Carbon Monoxide

CSB: Clean School Bus

CTRMA: Central Texas Regional Mobility Authority

CTT: Clean Transportation Triangle

DACM: Drive a Clean Machine

DERI: Diesel Emission Reduction Incentive

DFW: Dallas-Fort Worth

DTIP: Drayage Truck Incentive Program

EAC: Early Action Compact

EE/RE: Energy efficiency and renewable energy

EPA: U.S. Environmental Protection Agency

ERIG: Emission Reduction Incentive Grant Program

I/M: Inspection and maintenance

ILA: Inter-Local Agreement

LCRA: Lower Colorado River Authority

LSCFA: Lone Star Clean Fuels Alliance

LIP: Local Initiative Project

LIRAP: Low-Income Vehicle Repair, Retrofit, and Accelerated Vehicle Retirement Program

MDA8: Maximum Daily 8-Hour Average

µg/m3: Microgams per cubic meter

MOVES: Motor Vehicle Emissions Simulator

MSA: Metropolitan Statistical Area

NAAQS: National Ambient Air Quality Standards

NOX: Nitrogen oxides

NO2: Nitrogen dioxide

NTIG: New Technology Implementation Grant

O3: Ozone

OAD: Ozone Action Day

OAP: Ozone Advance Program

PACE: Property-Assessed Clean Energy

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Pb: Lead

PM2.5: Particulate matter with a diameter of 2.5 microns or less

PM10: Particulate matter with a diameter of 10 microns or less

PPB: Parts per billion

PPM: Parts per million

SIP: State Implementation Plan

SO2: Sulfur dioxide

TCEQ: Texas Commission on Environmental Quality

TERP: Texas Emission Reduction Plan

TCFP: Texas Clean Fleet Program

TMRS: Texas Municipal Retirement System

TNGVGP: Texas Natural Gas Vehicle Grant Program

TxDOT: Texas Department of Transportation

TexN: Texas NONROAD Model

VOC: Volatile Organic Compound

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1 Air Quality Status

This section provides an update on the status of air quality in the Austin-Round Rock MSA through the

end of 2016. It includes:

A general overview of air quality in the region;

Information on the region’s compliance with the NAAQS for all criteria pollutants;

Information on the fourth-highest ozone measurements at all monitoring stations in the region for

2014-2016;

A comparison of daily air pollution levels compared to EPA’s AQI for 2016;

An estimate of peak seasonal ozone exposure at each monitoring station; and

An analysis of the predictability of regional air pollution levels based on comparisons of actual air

pollution measurements in 2016 to TCEQ’s Ozone Action Day (OAD) forecasts and daily air quality

forecasts.

Air quality data collected in the Austin-Round Rock MSA between 2014 and 2016 shows that the region

remains in compliance with all NAAQS, and TCEQ’s Toxicological Evaluation of volatile organic

compounds (VOC) measurements collected in the region indicates that all concentrations were below

the agency’s “Air Monitoring Comparison Values.”1 There was 1 day when ozone levels exceeded the 70

ppb level of the 2015 Ozone NAAQS compared with 12 days over 70 ppb in 2015, and there were 98

days when air pollution levels were considered “Moderate” or worse in the region according to the

EPA’s Air Quality Index (AQI), a decrease from 153 days in 2015. The region’s air pollution levels were

better in 2016 than 2015, and were better than four other large metro areas of the state (Dallas-Fort

Worth, Houston, San Antonio, and El Paso), however, there are still air pollution problems in the region,

and the region’s ozone levels remain close to the 2015 ozone NAAQS.

The following map shows the locations of all of the Continuous Air Monitoring Stations (CAMS) that

collect air pollution samples in and near the Austin-Round Rock MSA, including the monitors operated

by TCEQ, CAPCOG, St. Edward’s University, and the Alamo Area Council of Governments (AACOG).

1 https://www.tceq.texas.gov/assets/public/implementation/tox/monitoring/evaluation/2015/reg11.pdf

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Figure 1-1. 2016 Air Quality Monitors in the Austin-Round Rock MSA and Nearby Counties

1.1 Compliance with the NAAQS The Austin-Round Rock’s 2016 design values for nitrogen dioxide (NO2), ground-level ozone (O3), fine

particulate matter (PM2.5), coarse particulate matter (PM10), and sulfur dioxide (SO2) were all in

compliance with the applicable NAAQS. There is no 2016 CO design value since data collection was

suspended in November 2014, and there is no lead design value for the region, since lead monitoring is

not conducted in the region. There are four monitoring stations that TCEQ used for collecting ambient

pollution concentrations used for comparisons to the NAAQS in 2014-2016.

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Table 1-1. Summary of Criteria Pollutant Measurement Periods at Federal Reference Method (FRM) Monitors in the Austin-Round Rock MSA, 2014-2016

Pollutant CAMS 3

(AQS Site Number 484530014)

CAMS 38 (AQS Site Number

484530020)

CAMS 171 (AQS Site Number

484530021)

CAMS 1068 (AQS Site Number

484531068)

CO Jan. – Nov. 2014 n/a n/a n/a

NO2 2014 – 2016 n/a n/a Apr. 2014 – 2016

O3 2014 – 2016 2014 – 2016 n/a n/a

PM2.5 n/a 2014 – 2016 2014 – 2016 n/a

PM10 n/a 2014 – 2016 2014 – 2016 n/a

SO2 2014-2016 n/a n/a n/a

The 2016 design values were calculated by CAPCOG, while 2015 design values (except for PM10) are

based on data from EPA’s design value website at https://www.epa.gov/air-trends/air-quality-design-

values.

Table 1-2. Austin-Round Rock MSA Criteria Pollutant Design Values Compared to Primary NAAQS

NAAQS Concentration 2014 Design

Value 2015 Design

Value 2016 Design

Value

CO – 1 hr. 35 ppm 0.5 ppm n/a n/a

CO – 8 hr. 9 ppm 0.3 ppm n/a n/a

NO2 –Annual Mean 53 ppb 5 ppb 15 ppb2 15 ppb

NO2 –1-hr. 100 ppb n/a 32 ppb 48 ppb

O3 – 8-hr. 0.070 ppm 0.069 ppm 0.068 ppm 0.066 ppm

PM2.5 – Annual Mean

12.0 µg/m3 9.4 µg/m3 9.2 µg/m3 9.6 µg/m3

PM2.5 – 24-hr. 35 µg/m3 24 µg/m3 22 µg/m3 21 µg/m3

PM10 –24-hr.3 150 µg/m3 58 µg/m3 68 µg/m3 71 µg/m3

SO2 –1-hr. 75 ppb n/a 5 ppb 4 ppb

The following figure shows the region’s 2014, 2015, and 2016 design values as a percentage of the

NAAQS in order to provide a comparison of the extent to which the region is in compliance with each

NAAQS. As the figure shows, the Austin-Round Rock MSA’s O3 levels are compliant, but just barely. After

O3, annual PM2.5 levels are the closest to the NAAQS, followed by 24-hour PM2.5 levels, both of which are

2 The increase in the design value from 2014 to 2015 reflects the fact that 2015 was the year in which data collected at Austin’s near-road NO2 monitor (CAMS 1068) could be used for this design value, since it began collecting data in April 2014 and there must be at least 75% data completeness in each quarter for an annual NO2 mean to be used for a design value. The annual NO2 design value at CAMS 3 decreased in 2015 to 4 ppb from 5 ppb in 2014 and 6 ppb in 2013. 3 The actual form of the standard is based on the number “expected exceedances,” which is calculated based on the average number of days that a monitor measured an exceedance of 150 µg/m3 per year over a 3-year period. Since the standard limits this average to 1, it means that the 4th highest 24-hour average would need to be at or below 150 µg/m3. Expressing the PM10 design value in this way allows an easier comparison of the region’s air quality as a percentage of the NAAQS.

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more than 50% of the NAAQS. The region’s 1-hour and 8-hour CO levels, 1-hour NO2 levels, annual NO2

levels, 24-hour PM10 levels, and 1-hour SO2 levels are all less than 50% of the applicable NAAQS.

Figure 1-2. Austin-Round Rock MSA Design Values as a percentage of NAAQS

While the region’s 2014-2016 O3 design value remains close to the level of the 2015 O3 NAAQS, ozone

design values continued to decline for the sixth consecutive year and the. The figure below shows the

trend in the region’s design value over this period, along with the levels of the 1997, 2008, and 2015 O3

NAAQS. Looking forward, ongoing turnover of older on-road and non-road engines and the gradual

replacement of older power plants with newer, lower-emitting plants are expected to reduce NOX

emissions in the region and across the country, which should continue to drive ozone levels down within

the region.

The figure below shows the trend in the Austin-Round Rock MSA’s 8-hour O3 design values from 1999-

2016 compared to the 1997, 2008, and 2015 8-hour O3 NAAQS. Over this time, the region’s design value

has decreased an average of 1.4 ppb per year. Key design values that were used in the area designation

process for these NAAQS are highlighted in green:

The region’s 2003 design value was used as the basis for the EPA’s initial area designation for

the 1997 O3 NAAQS in April 2004, although through the Early Action Compact (EAC) process,

final action on this designation was deferred until after 2007

The region’s 2007 design value was required to be in attainment of the 1997 O3 NAAQS as part

of the EAC

1% 3%

9%

99%

78%

69%

39%

28%32%

97%

77%

63%

45%

7%

28%

48%

94%

80%

60%

47%

5%

CO 1-hr CO 8-hr NO2 annual NO2 1-hr O3 PM2.5annual

PM2.5 daily PM10 daily SO2 1-hr

2014 2015 2016

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The region’s 2010 design value was used as the basis for the region’s designation for the 2008

O3 NAAQS following EPA’s delay in issuing initial area designations due to its reconsideration of

the 2008 O3 NAAQS.

Figure 1-3. Austin-Round Rock MSA 8-Hour Ozone Design Value 1999-2016

The region’s 2014-2016 design value was originally thought to be the key design value that would be

used for initial area designations for the 2015 O3 NAAQS, but on June 6, 2017, the EPA Administrator

announced that the EPA would be delaying initial area designations by one year, pushing the date back

to October 1, 2018, and also likely pushing the key design value period back to 2015-2017. As of the

date of this report, the Austin-Round Rock MSA’s 2015-2017 design value would be 68 ppb, but it

remains highly unlikely that the region’s 2015-2017 design value would exceed 70 ppb. The region

would need a 4th-highest maximum daily 8-hour O3 average at CAMS 3 to be at least 76 ppb or the 4th-

highest maximum daily 8-hour O3 average at CAMS 38 to be at least 78 ppb in order for Travis County’s

2015-2017 design value to exceed 70 ppb, and the region has not had O3 levels that high since 2009 and

2006, respectively.

1.2 Maximum Daily 8-Hour Ozone Averages in the Region

While compliance with the ozone NAAQS is based on readings recorded at “regulatory” Federal

Reference Method (FRM) or Federal Equivalent Method (FEM) ozone samplers, there are also a number

of non-regulatory ozone monitoring stations in the region that can be used to understand regional

ozone levels.

89 8988

8584

85

82 8280

7775

7475

7473

6968

66

60

65

70

75

80

85

90

95

8-H

ou

r O

zon

e D

esig

n V

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1997 Standard 2008 Standard 2015 Standard Design Value

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In addition to the two regulatory ozone monitors that TCEQ operates, CAPCOG collected ozone data at

nine monitoring stations between 2014 and 2016. These use EPA-approved ozone sampling methods

and data collected during this period followed a Quality Assurance Project Plan (QAPP) approved by

TCEQ, but were not operated as FRM or FEM monitors, and these monitors are not included in TCEQ’s

Annual Monitoring Network Plan that is approved by EPA.

The following table summarizes the fourth-highest MDA8 ozone measurements collected at each

monitoring station in the CAPCOG region 2013, 2014, and 2015, as well as the three-year average for

each station. CAMS 3 and 38 are the “regulatory” monitoring stations operated by TCEQ, while CAMS

601, 614, 684, 690, 1603, 1604, 1605, 1675, and 6602 are research monitoring stations operated by

CAPCOG. Reports documenting the quality-checks performed at these sites can be found on CAPCOG’s

website at http://www.capcog.org/divisions/regional-services/aq-reports.

Table 1-3. Fourth-highest MDA8 Measurements at All Ozone Monitoring Stations in the CAPCOG Region, 2014-2016 (ppb)

CAMS AQS Site Number

County 2014 2015 2016 2014-2016

Average

3 484530014 Travis 62 73 64 66.3

38 484530020 Travis 63 73 62 66.0

601 481490601 Fayette 69 70 59 66.0

614 482090614 Hays 63 71 65 66.3

684 480210684 Bastrop 53 69 59 60.3

690 484910690 Williamson 66 75 61 67.3

1603 484531603 Travis 57 72 63 64.0

1604 480551604 Caldwell 64 67 60 63.7

1605 484531605 Travis N/A N/A *52 *52

1675 482091675 Hays 61 70 62 64.3

6602 484916602 Williamson *39 71 58 *64.5

CAMS 1605 was installed by St. Edward’s University at their campus in Austin ahead of the 2016

O3 season in order to support scientific research involving the launching of “ozonesondes” to

collect vertical measurements of O3 on predicted high ozone days. Throughout the 2016 O3

season, the monitor recorded lower than expected ambient O3 measurements for the vicinity

based on analysis of modeling data and comparisons to the nearby CAMS 1603 monitor.

Following a series of quality-checks, St. Edward’s University researchers determined that the O3

data at CAMS 1605 was accurate and precise, but believed that values were likely lower than

expected due to some NOX titration issues on campus where the monitor is located (less than 1

kilometer from IH-35, U.S.-71, and Congress Avenue, causing a potentially high localized

concentration of NOX on campus).4 The CAMS 1605 data is therefore reliable for ground-level

4 On days in 2016 when at either CAMs 1603 or CAMS 1605 had MDA8 values of of 55 ppb or higher, CAMS 1605 had MDA8 values that were, on average, 10.6 ppb lower than CAMS 1603, with a range of 2-19 ppb below the values at CAMS 1603. Modeling results from release 2 of the June 2012 episode available from TCEQ, on the other hand, showed that CAMS 1605 was only 1.1 ppb lower, on average, than CAMS 1603 when either site had MDA8 values of 55 ppb or higher, ranking from 3.5 below to 10.6 ppb above.

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verification of the ozonesonde measurements, but not a good indication of neighborhood-level

exposure of ozone in the vicinity of the monitor.

CAMS 6602 was physically located in a different location on the campus of Hutto Independent

School District’s administration facility in 2014 than it was in 2015 and 2016. CAPCOG believes

that the 2014 data – while accurate – is not representative of the neighborhood-level O3

exposure due to NOX titration from vegetation or other interference near the inlet of the O3

instrument in 2014. As the 2014 monitoring report documents, possible alternative explanations

for substantially lower readings at CAMS 6602 than were expected based on other monitors in

the region, modeling results, and the prior year’s readings were ruled out through supplemental

quality-assurance/quality control work performed by Dios Dado Environmental, Ltd. on that

station.5

Google earth maps of CAMS 1605 and CAMS 6602 below illustrate the proximity of each station to these

potential problems.

Figure 1-4. Map of CAMS 1605 and vicinity

5 http://www.capcog.org/documents/airquality/reports/2014/Task_3-2_2014_CAPCOG_Monitoring_Report_Final.pdf , p. 100. “The persistence of low readings at CAMS 6602, despite changing out the sample line and using two separate instruments to record data, indicates that the low ozone levels are likely due to the site location, which may be resulting in some scrubbing action from nearby interference factors, such as trees, forced air vents, or any number of ozone scrubbing activities that can occur.”

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Figure 1-5. Map of locations of sampling equipment at CAMS 6602, 2011-2016

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Figure 1-6. Close-up aerial photography of the location of CAMS 6602 sampling equipment in October 2014

These data generally show that the 2014-2016 three-year average of the fourth highest MDA8 values in

the region ranged from 60 ppb – 67 ppb. However, the data also show significant variability in these

values year-to-year, with the fourth highest MDA8 values for 2015 exceeding 70 ppb at all six of ten

locations in 2015.

1.3 Daily Pollution Levels Compared to EPA’s AQI

While regulatory compliance is an important indicator of a region’s air quality, it is possible for an area

to experience numerous exceedances of an air pollution level that exceed the level of the NAAQS

multiple times in a given year and still have a compliant design value. A design value also does not

directly indicate how frequently a region experienced high pollution levels. Another indicator that can

be used to characterize a region’s air quality is the number of days a region experiences air pollution

levels fall within each of the AQI categories established by EPA. The following table shows the

concentrations of NO2, O3, and PM2.5 that correspond to each AQI level.6

Table 1-4. Summary of AQI for NO2, O3, and PM2.5

AQI Level AQI Number NO2

(1-Hr., ppb) O3

(8-Hr., ppb) PM2.5

(24 hr., µg/m3)

Good 0-50 0-53 0-54 0.0-12.0

Moderate 51-100 54-100 55-70 12.1-35.4

6 There were no days when PM10, SO2, or CO AQIs were above 50, so those values are excluded from this table.

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AQI Level AQI Number NO2

(1-Hr., ppb) O3

(8-Hr., ppb) PM2.5

(24 hr., µg/m3)

Unhealthy for Sensitive Groups 101-150 101-360 71-85 35.5-55.4

Unhealthy 151-200 361-649 86-105 55.5-150.4

Very Unhealthy 201-300 650-1,249 106-200 150.5-250.4

Hazardous 301-500 1,250-2,049 201-600 250.5-500

This report includes data from all of the air pollution monitoring stations in the region, not just the TCEQ

regulatory monitors that are used for formal AQI reporting to TCEQ. Therefore, the number of days in

the “moderate” category described below are higher than if only the TCEQ regulatory monitors were

used.

The following figures show the number of days in 2016 when NO2, PM2.5, or O3 concentrations measured

in the CAPCOG region were high enough to be considered Moderate or Unhealthy for Sensitive Groups.

There were some days when AQI levels were above 50 for more than 1 pollutant, so the “any pollutant”

bar below reflects the total number of days when the overall AQI for the region was at least 50. There

were no days with AQI values of 151 or higher recorded in the CAPCOG region in 2016. There was only 1

day when AQI levels exceeded 100 in 2016, down substantially from the 12 days in 2015, but more than

the 0 days when AQI levels exceeded 100 in 2014.

Figure 1-7. Number of "Moderate" or ”Unhealthy for Sensitive Groups” Air Pollution Days in the CAPCOG Region in 2016 by Pollutant

1

60

45

971

1

NO2 PM2.5 O3 Any Pollutant

Moderate Unhealthy for Sensitive Groups

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There was one day when at least one ozone monitor in the region measured ozone concentrations

considered Unhealthy for Sensitive Groups. While the region only reached levels considered Unhealthy

for Sensitive Groups for ozone, over half of the days when air pollution reached levels considered

Moderate or worse were due to elevated NO2 or PM2.5 concentrations. Finally, while the region’s air

pollution levels were considered Good on a majority of the days in 2016, they were Moderate or worse

on 27% of the days in 2016. While “moderate” air pollution levels are not exceeding the level of the

NAAQS, and the number of people affected by air pollution levels in this range is very small, there is a

very small part of the population unusually sensitive to air pollution that could potentially have

experienced health issues related to air pollution exposure on about 1 out of every 4 days in 2016.

1.3.1 High Ozone AQI Days

The following figures show the number of days when O3 levels were considered moderate or unhealthy

for sensitive groups at each monitoring station in the region in 2016. CAMS 3 in Travis County measured

the one and only MDA8 value over 70 ppb. All other CAMS measured no MDA8 values over 70 ppb.

Figure 1-8. Number of Days when Ozone Pollution was "Moderate" or Worse by Monitoring Station and County, 2016

1.3.2 High PM2.5 AQI Days

The figure below shows the number of days when PM2.5 levels were considered Moderate at each

monitoring station. The location with the highest number of Moderate days for PM2.5 was CAMS 326,

3428

22

8

20 23 23

2

16 15

Moderate Unhealthy for Sensitive Groups

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which is located at Zavala Elementary School in Austin. The highest 24-hour PM2.5 average in 2015 was

recorded on July 11, 2016, when CAMS 171 (located in East Austin on Webberville Road) had a 24-hour

average of 28.3 µg/m3 (81% of the level of the 24-hour PM2.5 NAAQS).

Figure 1-9. Number of Days when PM2.5 Pollution was "Moderate" or Worse by Monitoring Station and County, 2016

1.3.3 Distribution of Moderate or Worse AQI Days by Month

Air pollution levels vary significantly by season in the CAPCOG region. In 2016, air pollution levels were

considered Moderate over 50% of the days in April, and as low as 3% in January. The AQI only exceeded

100 once during the season, in October. In 2015, by contrast, there was 1 day when the AQI exceeded

100 in April, 2 in May, 6 in August, and 3 in October.

3732

45

53

CAMS 3 (Travis Co.) CAMS 38 (Travis Co.) CAMS 171 (Travis Co.) CAMS 326 (Travis Co.)

Moderate

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Figure 1-10. Number of Days when Air Pollution was "Moderate" or Worse in the CAPCOG Region by Month, 2016

1.4 Seasonal Ozone Exposure

While EPA set the 2015 secondary O3 standard identical to the 2015 primary O3 standard, the preamble

to the rulemaking states that, “the requisite protection will be provided by a standard that generally

limits cumulative seasonal exposure to 17 ppm-hours (ppm-hrs) or lower, in terms of a 3-year W126

index.” EPA did not set a separate secondary standard set to protect public welfare, as opposed to

public health, because, “such control of cumulative seasonal exposure will be achieved with a standard

set at a level of 0.070 ppm, and the same indicator, averaging time, and form as the current standard.”

The region’s peak seasonal O3 exposure levels were 22-70% below the 17 ppm-hr levels EPA referenced

in the final 2015 O3 NAAQS rulemaking. The figure below shows the 3-month seasonal exposure levels at

each monitoring station by month (the month on the x-axis corresponds with the final month in the 3-

month sum).

1

4

12

16

1213

12

7

10

5

23

1

Jan. Feb. Mar. Apr. May Jun. Jul. Aug. Sep. Oct. Nov. Dec.

Moderate Unhealthy for Sensitive Groups

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Figure 1-11. Weighted Seasonal Ozone Exposure by Monitoring Station and 3-month period, 2016 (W126 ppm-hrs)

1.5 Air Quality Forecasting

One of the factors that influences the risks associated with air pollution is the extent to which air

pollution can be accurately and successfully predicted. For the Austin area, there are two types of

forecasting tools that can be used to help reduce the exposure of sensitive populations to high air

pollution levels – Ozone Action Days (OADs) and daily Air Quality Forecasts.

1.5.1 Ozone Action Days

TCEQ issues OADs the afternoon before a day when it believes that ozone levels may exceed the level of

the NAAQS. While the level of the Ozone NAAQS changed on October 1, 2015, states were required to

start reporting AQI in terms of the new Ozone NAAQS starting January 1, 2016. Therefore, 2016 was the

first year for which the new ozone AQI thresholds were used. Therefore, it is important to understand

that the data analysis in this section includes both forecast data using the 2008 ozone AQI and forecast

data using the 2015 AQI. TCEQ issued two OADs for the Austin-Round Rock area in 2016 (for April 23,

2016, and for May 6, 2016), and one day when Ozone MDA8 exceeded 70 ppb (October 3, 2016).

There are two ways CAPCOG has measured the performance of OAD forecasting for the region over the

past several years – accuracy in correctly predicting an OAD, and success in predicting when actual

monitored ozone levels were high enough to be considered unhealthy for sensitive groups.

0

2

4

6

8

10

12

14

16

18

Jan-Mar Feb-Apr Mar-May Apr-Jun May-Jul Jun-Aug Jul-Sep Aug-Oct Sep-Nov Oct-Dec

Seas

on

Ozo

ne

Exp

osu

re (p

pm

-hrs

)

2015 Ozone NAAQS - Equivalent Level CAMS 3

CAMS 38 CAMS 614

CAMS 684 CAMS 690

CAMS 1603 CAMS 1604

CAMS 1675 CAMS 6602

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Using the new AQI for ozone, CAPCOG calculates these metrics as follows:

𝑂𝐴𝐷 𝐴𝑐𝑐𝑢𝑟𝑎𝑐𝑦 𝑅𝑎𝑡𝑒 = 𝐷𝑎𝑦𝑠 𝑂𝐴𝐷 𝐷𝑒𝑐𝑙𝑎𝑟𝑒𝑑 𝑊ℎ𝑒𝑛 𝐴𝑐𝑡𝑢𝑎𝑙 𝑀𝐷𝐴8 > 70 𝑝𝑝𝑏

𝐷𝑎𝑦𝑠 𝑂𝐴𝐷 𝐷𝑒𝑐𝑙𝑎𝑟𝑒𝑑

𝑂𝐴𝐷 𝑆𝑢𝑐𝑐𝑒𝑠𝑠 𝑅𝑎𝑡𝑒 = 𝐷𝑎𝑦𝑠 𝑂𝐴𝐷 𝐷𝑒𝑐𝑙𝑎𝑟𝑒𝑑 𝑊ℎ𝑒𝑛 𝐴𝑐𝑡𝑢𝑎𝑙 𝑀𝐷𝐴8 > 70 𝑝𝑝𝑏

𝐷𝑎𝑦𝑠 𝑊ℎ𝑒𝑛 𝐴𝑐𝑡𝑢𝑎𝑙 𝑀𝐷𝐴8 > 70 𝑝𝑝𝑏

Using these metrics means that TCEQ’s OAD forecasting efforts for the region in 2016 were 0% accurate

(zero out of two forecasts for an exceedance of 70 ppb were incorrect), and the agency missed 100% of

the days (one out of one) when ozone levels were actually over 70 ppb.

Note that, to the extent that TCEQ’s two OADs may prompt individuals in the region to take action to

reduce emissions, it is possible that the ozone AQI levels would have exceeded 100 if not for the OAD.

For example, on– April 23, 2016, the highest ozone MDA8 in the region was 69 ppb, corresponding to an

AQI level of 99. It is possible that the action taken by residents of Central Texas on this date accounted

for the difference between this day’s ozone levels being 69 ppb and 71 ppb. This is less likely for and

May 6, 2016, when the highest MDA8 value recorded in the region was 62 ppb.

These metrics are only accounting for days when either a forecast was for > 70 ppb or actual ozone was

>70 ppb, and does not account for the other 362 days in 2016 when TCEQ correctly did not issue an OAD

and ozone did not exceed 70 ppb.

From 2014-2016, TCEQ issued a total of four OAD alerts for the Austin-Round Rock area – one in 2014,

one in 2015, and two in 2016. During this time frame, there were a total of five days when ozone levels

exceeded the level of the Ozone NAAQS: 0 in 2014, 4 in 2015, and 1 in 2016. The following table lists

each of these dates.

Table 1-5. OAD Dates and Dates when O3 Exceeded Level of NAAQS, 2014-2016

Date OAD Issued for this

Date? O3 NAAQS Level in

Effect

Highest O3 MDA8 Value Recorded in

MSA

Station where Highest O3 MDA8 Value Recorded

8/14/14 Yes 75 ppb 63 ppb CAMS 614

8/13/15 No 75 ppb 76 ppb CAMS 3

8/27/15 Yes 75 ppb 82 ppb CAMS 3

8/28/15 No 75 ppb 85 ppb CAMS 3

8/29/15 No 75 ppb 83 ppb CAMS 3

4/23/16 Yes 70 ppb 69 ppb CAMS 38

5/6/16 Yes 70 ppb 62 ppb CAMS 1603

10/3/16 No 70 ppb 72 ppb CAMS 3

One of these forecasts correctly predicted ozone levels over the NAAQS in effect at the time the

applicable NAAQS (the 2008 Ozone NAAQS in 2014 and 2015, the 2015 Ozone NAAQS in 2016) in the

region on the following day – a 25% accuracy rate. Conversely, there were a total of five days from 2014-

2016 when MDA8 levels exceeded the level of the NAAQS, one of which was forecast as an OAD, a 20%

success rate.

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Figure 1-12. Ozone Action Day Forecast Accuracy and Success, 2014-2016

1.5.2 Daily Air Quality Forecasts

Unlike OADs, which are only issued for days when TCEQ believes O3 will reach levels considered

unhealthy for sensitive groups; daily air quality forecasts include forecasts for “good” and “moderate”

air pollution levels as well, and include forecasts for pollutants other than O3. The performance of these

forecasts can also be measured using the same type of metrics used above for OADs – accuracy and

success. In this case, CAPCOG evaluated the accuracy and success rate in terms of the number of days

when air quality was forecast to be moderate or worse. The equations below explain these terms in

terms of the daily AQI forecast.

𝐴𝑄𝐼 𝐹𝑜𝑟𝑒𝑐𝑎𝑠𝑡 𝐴𝑐𝑐𝑢𝑟𝑎𝑐𝑦 𝑅𝑎𝑡𝑒

= 𝐷𝑎𝑦𝑠 𝑊ℎ𝑒𝑛 𝐴𝑄𝐼 𝐹𝑜𝑟𝑒𝑐𝑎𝑠𝑡 𝑡𝑜 𝑏𝑒 𝑀𝑜𝑑𝑒𝑟𝑎𝑡𝑒 𝑜𝑟 𝑊𝑜𝑟𝑠𝑒 𝑎𝑛𝑑 𝑤𝑎𝑠 𝐴𝑐𝑡𝑢𝑎𝑙𝑙𝑦 𝑀𝑜𝑑𝑒𝑟𝑎𝑡𝑒 𝑜𝑟 𝑊𝑜𝑟𝑠𝑒

𝐷𝑎𝑦𝑠 𝐹𝑜𝑟𝑒𝑐𝑎𝑠𝑡 𝑡𝑜 𝑏𝑒 𝑀𝑜𝑑𝑒𝑟𝑎𝑡𝑒 𝑜𝑟 𝑊𝑜𝑟𝑠𝑒

𝐴𝑄𝐼 𝐹𝑜𝑟𝑒𝑐𝑎𝑠𝑡 𝑆𝑢𝑐𝑐𝑒𝑠𝑠 𝑅𝑎𝑡𝑒

= 𝐷𝑎𝑦𝑠 𝑊ℎ𝑒𝑛 𝐴𝑄𝐼 𝐹𝑜𝑟𝑒𝑐𝑎𝑠𝑡 𝑡𝑜 𝑏𝑒 𝑀𝑜𝑑𝑒𝑟𝑎𝑡𝑒 𝑜𝑟 𝑊𝑜𝑟𝑠𝑒 𝑎𝑛𝑑 𝑤𝑎𝑠 𝐴𝑐𝑡𝑢𝑎𝑙𝑙𝑦 𝑀𝑜𝑑𝑒𝑟𝑎𝑡𝑒 𝑜𝑟 𝑊𝑜𝑟𝑠𝑒

𝐷𝑎𝑦𝑠 𝑊ℎ𝑒𝑛 𝐴𝑐𝑡𝑢𝑎𝑙 𝐴𝑄𝐼 𝑊𝑎𝑠 𝑀𝑜𝑑𝑒𝑟𝑎𝑡𝑒 𝑜𝑟 𝑊𝑜𝑟𝑠𝑒

Since the daily AQI forecasts for the region included forecasts for both O3 and PM2.5, it is possible to

analyze these accuracy and success rates by pollutant, as well as for the overall AQI. The figure below

shows the results of this analysis for 2016.

1

1

3

14

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

OAD Days Days when MDA8 > 70 ppb

Forecast Correct Forecast Not Correct

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Figure 1-13. Accuracy and Success of AQI Forecasts for 2016

Overall, TCEQ’s forecasts for O3 levels to be moderate or worse were 51% accurate (actual O3 levels

were good 49% of the time TCEQ made a forecast for O3 to be moderate or worse) and 47% successful

(53% of days when actual O3 levels were moderate or worse has been forecast to have good O3 levels).

The accuracy and success rates for PM2.5 forecasting were lower – 39% and 27%, respectively. Overall,

the AQI forecasts were 54% accurate and 45% successful.

2 Regional Ozone-Forming Emissions This section provides information on ozone-forming emissions in the Austin-Round Rock area and their

estimated impact on ambient ozone levels.

2.1 Impact of NOX Emissions v. VOC Emissions on Ozone Concentrations Modeling conducted by AACOG for CAPCOG of projected 2017 ozone levels showed that NOX emissions

account for 97.9-99.7% of the impact from anthropogenic emissions from the Austin-Round Rock MSA

on maximum daily 8-hour ozone averages on high ozone days. The figure below shows the contributions

at each of the seven monitoring stations in the region that were analyzed.

23 2316

16

4444

22 2625

44

3853

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Moderate orWorse Ozone

Forecast

Actual OzoneLevels Moderate

or Worse

Moderate orWorse PM2.5

Levels Forecast

Actual PM2.5Levels Moderate

or Worse

Moderate orWorse OverallAQI Forecast

Actual AQIModerate or

Worse

Forecast Correct Forecast Not Correct

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Figure 2-1. Modeled Impact of Anthropogenic NOX and VOC Emissions from the Austin-Round Rock MSA on High O3 Days

Using these contribution estimates and EPA’s 2017 NOX emissions estimates for each county (estimated

to be 5.57 tpd, 4.89 tpd, 13.63 tpd, 30.54 tpd, and 11.77 tpd for Bastrop, Caldwell, Hays, Travis, and

Williamson Counties, respectively, for a total of 66.39 tpd), the following table shows an approximate

ratio of ozone contribution to NOX emissions for each county to each of the monitoring stations

analyzed.

16.20 15.39

10.7412.84

15.85

8.86 8.86

0.180.14

0.04

0.15

0.07

0.11 0.19

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

16.00

18.00

CAMS 3 CAMS 38 CAMS 614 CAMS 690 CAMS1603

CAMS1675

CAMS6602

Mo

del

ed Im

pac

t o

n M

axim

um

Dai

ly 8

-H

ou

r O

zon

e A

vera

ges

(pp

b)

NOX VOC

16.20 15.39

10.7412.84

15.85

8.86 8.86

0.180.14

0.04

0.15

0.07

0.11 0.19

0.00

2.00

4.00

6.00

8.00

10.00

12.00

14.00

16.00

18.00

CAMS 3 CAMS 38 CAMS 614 CAMS 690 CAMS1603

CAMS1675

CAMS6602

Mo

del

ed Im

pac

t o

n M

axim

um

Dai

ly 8

-H

ou

r O

zon

e A

vera

ges

(pp

b)

NOX VOC

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Table 2-1. Average 2017 Ozone Concentration Contribution per TPD of NOX Emissions

County CAMS 3 CAMS 38 CAMS 614 CAMS 690 CAMS 1603

CAMS 1675

CAMS 6602

Bastrop 0.23 0.18 0.13 0.23 0.23 0.15 0.26

Caldwell 0.08 0.09 0.19 0.07 0.15 0.32 0.04

Hays 0.10 0.13 0.30 0.07 0.19 0.22 0.06

Travis 0.40 0.36 0.16 0.27 0.34 0.10 0.17

Williamson 0.08 0.09 0.02 0.16 0.06 0.03 0.11

TOTAL 0.24 0.23 0.16 0.19 0.24 0.13 0.13

These data show that NOX emissions from Travis County have about 1.72-5.20 the impact on peak O3

concentrations at the two regulatory O3 monitors in the region as NOX emissions from any of the other

counties in the region.

2.2 2016 Regional Ozone Season Weekday NOX Emissions Profile The following pie chart shows the general break-down of anthropogenic NOX emissions in the region by

major source type – on-road mobile, non-road mobile, point source, and area source emissions.

Figure 2-2. 2016 Ozone Season Weekday NOX Emissions for the Austin-Round Rock MSA (tpd)

2.2.1 NOX Emissions by Source Type by County

The following table shows the break-down of the region’s NOX emissions by county and source type.

On-Road38.6849%

Non-Road17.8323%

Point15.7520%

Area6.068%

Total = 78.31 tpd NOX Emissions

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Table 2-2. 2016 Ozone Season Weekday NOX Emissions by Source Type and County

County On-Road Non-Road Point Area Total

Bastrop 2.40 1.53 3.29 0.37 7.59

Caldwell 1.39 1.17 0.66 1.86 5.07

Hays 5.10 1.42 7.27 0.41 14.20

Travis 21.23 8.99 4.36 2.61 37.18

Williamson 8.56 4.73 0.17 0.81 14.27

TOTAL 38.68 17.83 15.75 6.06 78.31

2.2.2 On-Road Sector

The on-road sector includes mobile sources that are registered to operate on public roads. On-road

vehicles remain the largest source of NOX emissions within the region, accounting for 38.68 tons per day

(tpd) of NOX emissions on a typical 2016 ozone season weekday. The table below shows the typical 2016

ozone season weekday NOX emissions for the region by source use type.

Table 2-3. 2016 Austin-Round Rock Ozone Season Weekday NOX Emissions by Source Use Type

Source Use Type NOX (tpd)

Motorcycle 0.03

Passenger Car 12.01

Passenger Truck 8.17

Light Commercial Truck 2.37

Intercity Bus 0.18

Transit Bus 0.25

School Bus 0.49

Refuse Truck 0.45

Single-Unit Short-Haul Truck 2.39

Single-Unit Long-Haul Truck 0.26

Motor Home 0.22

Combination Short-Haul Truck 4.71

Combination Long-Haul Truck 7.14

TOTAL 38.68

Passenger cars and passenger trucks combined to account for 20.18 tpd of NOX emissions, while

commercial trucking accounted for 14.95 tpd NOX emissions, and the remaining sources accounting for

3.54 tpd NOX emissions, most of which come from light commercial trucks.

2.2.3 Non-Road Sources

The non-road sector consists of any mobile source that is not registered to be operated on a public road,

including sources such as agricultural equipment, construction and mining equipment, locomotives,

aircraft, and drill rigs. Non-road sources made up the 2nd-largest source of NOX emissions within the

region in 2016, accounting for 17.83 tpd of NOX emissions on a typical ozone season weekday. The non-

road sector includes any mobile source not registered to operate on a public roadway. There are four

different TCEQ “trends” data sets from which CAPCOG extracted non-road emissions estimates:

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equipment modeled in the “Texas NONROAD” (TexN) model, locomotives/rail equipment, aircraft

(including ground support equipment), and drill rigs.

Table 2-4. 2016 Ozone Season Weekday Non-Road NOX Emissions by County (tpd)

County TexN Rail Aircraft Drill Rigs Total

Bastrop 1.06 0.46 0.00 0.00 1.53

Caldwell 0.64 0.50 0.01 0.02 1.17

Hays 0.96 0.46 0.00 0.00 1.42

Travis 6.26 0.45 2.28 0.00 8.99

Williamson 4.16 0.55 0.02 0.00 4.73

TOTAL 13.08 2.43 2.30 0.02 17.83

2.2.4 Point Sources

The point source sector consists of any stationary source that reports its emissions to TCEQ. The most

recent point source data that is publicly available from TCEQ is for 2015. In that year there were 30

facilities from the Austin-Round Rock MSA that reported their emissions to TCEQ, accounting for a total

of 16.27 tpd of NOX emissions. Since EPA makes data for EGUs available online more quickly than TCEQ

publishes the annual emissions data it collects, 2016 EGU data are already available. Substituting the

2016 EGU data from EPA into the 2015 TCEQ emissions data brings the total to 16.91 tpd from point

sources. The following table combines the 2015 non-EGU emissions with the 2016 EGU emissions for a

combined 2015/2016 point source emissions estimate by county.

Table 2-5. 2015/2016 Ozone Season Weekday Point Source NOX Emissions by County (tpd)

County Non-EGU EGU TOTAL

Bastrop 0.11 3.18 3.29

Caldwell 0.66 0.00 0.66

Hays 6.54 0.73 7.27

Travis 3.72 1.80 5.52

Williamson 0.17 0.00 0.17

TOTAL 11.20 5.70 16.91

Table 5-6 below shows the 2015 NOX emissions by facility.

Table 2-6. 2015 Ozone Season Day Point Source Emissions in the Austin-Round Rock MSA

RN COMPANY SITE COUNTY NOX (tpd)

RN102038486 LOWER COLORADO RIVER

AUTHORITY SIM GIDEON POWER PLANT BASTROP 1.35

RN100212034 FORTERRA BRICK LLC ELGIN FACILITY BASTROP 0.04

RN100225846 ACME BRICK COMPANY ELGIN PLANT BASTROP 0.07

RN100723915 GENTEX POWER CORPORATION

LOST PINES 1 POWER PLANT BASTROP 0.60

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RN COMPANY SITE COUNTY NOX (tpd)

RN101056851 BASTROP ENERGY PARTNERS

LP BASTROP ENERGY CENTER BASTROP 1.15

RN100212018 DAVIS GAS PROCESSING, INC LULING GAS PLANT CALDWELL 0.27

RN100220177 OASIS PIPELINE CO TEXAS LP PRAIRIE LEA COMPRESSOR

STATION CALDWELL 0.39

RN105366934 FLINT HILLS RESOURCES

CORPUS CHRISTI LLC MUSTANG RIDGE TERMINAL CALDWELL 0.00

RN102597846 TEXAS LEHIGH CEMENT

COMPANY LP TEXAS LEHIGH CEMENT CO HAYS 6.54

RN100211689 HAYS ENERGY LLC HAYS ENERGY FACILITY HAYS 0.71

RN100219872 CITY OF AUSTIN ELECTRIC

UTILITY DEPARTMENT DBA AUSTIN ENERGY

DECKER CREEK POWER PLANT

TRAVIS 2.06

RN100214337 AUSTIN WHITE LIME COMPANY MCNEIL PLANT & QUARRY TRAVIS 0.01

RN105074561 APAC-TEXAS INC AUSTIN HOT MIX TRAVIS 0.03

RN100843747 NXP USA INC ED BLUESTEIN SITE TRAVIS 0.02

RN102533510 UNIVERSITY OF TEXAS AT

AUSTIN HAL C WEAVER POWER

PLANT TRAVIS 1.69

RN100723741 SPANSION LLC SPANSION AUSTIN FACILITY TRAVIS 0.02

RN102752763 NXP USA INC INTEGRATED CIRCUIT MFG

OAK HILL FAB TRAVIS 0.02

RN101957769 AUSTIN AMERICAN

STATESMAN AUSTIN AMERICAN

STATESMAN TRAVIS 0.00

RN100542752 BFI WASTE SYSTEMS OF

NORTH AMERICA INC BFI SUNSET FARMS LANDFILL TRAVIS 0.05

RN100218692 3M COMPANY 3M AUSTIN CENTER TRAVIS 0.08

RN100216746 AUSTIN COUNTER TOPS INC AUSTIN COUNTER TOPS TRAVIS 0.00

RN101059673 FLINT HILLS RESOURCES

CORPUS CHRISTI LLC AUSTIN TERMINAL TRAVIS 0.00

RN100215938 WASTE MANAGEMENT OF

TEXAS INC AUSTIN COMMUNITY

LANDFILL TRAVIS 0.11

RN101992246 SUNSET FARMS ENERGY LLC SUNSET FARMS ENERGY TRAVIS 0.09

RN100518026 SAMSUNG AUSTIN

SEMICONDUCTOR LLC AUSTIN FABRICATION

FACILITY TRAVIS 0.34

RN100215052 CITY OF AUSTIN ELECTRIC

UTILITY DEPARTMENT DBA AUSTIN ENERGY

SAND HILL ENERGY CENTER TRAVIS 0.40

RN102016698 TEXAS DISPOSAL SYSTEMS

LANDFILL INC TEXAS DISPOSAL SYSTEMS

LANDFILL TRAVIS 0.06

RN100225754 WASTE MANAGEMENT OF

NORTH TEXAS WILLIAMSON COUNTY

LANDFILL HUTTO WILLIAMSON 0.04

RN100725712 SEMINOLE PIPELINE COMPANY

LLC COUPLAND PUMP STATION WILLIAMSON 0.12

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RN COMPANY SITE COUNTY NOX (tpd)

RN100728179 DURCON LABORATORY TOPS

INCORPORATED DURCON LABORATORY TOPS

INCORPORATED WILLIAMSON 0.01

TOTAL n/a n/a n/a 16.27

The following table shows the estimates 2016 ozone season day NOX emissions for electric generating

units in the region. The NOX emissions for the Decker Creek Power Plant turbines is based on an

adjustment to the data reported to EPA due to certain acid rain data defaults that must be used in

absence of recent stack tests; the adjustment ensures that the emission rates are consistent with the

reported emissions rates in the facilities 2015 EIQ submitted to TCEQ.

Table 2-7. 2016 Austin-Round Rock MSA Electric Generating Unit Ozone Season Day NOX Emissions by Facility

Facility County NOX (tpd)

Bastrop Clean Energy Center Bastrop 1.07

Decker Creek Travis 2.16

Hays Energy Facility Hays 0.63

Lost Pines 1 Bastrop 0.46

Sand Hill Energy Center Travis 0.34

Sim Gideon Bastrop 1.65

TOTAL TOTAL 6.32

2.2.5 Area Sources

CAPCOG estimated the 2016 area sources using EPA’s 2017 emissions inventory projections used in

recent ozone modeling for its 2011v6.3 platform.7

Table 2-8. 2017 Area Source NOX Emissions by County and Type (tpd)

County Agricultural

Fires Non-Point

Non-Point Oil and Gas

Residential Wood

Combustion Total

Bastrop 0.0032 0.1864 0.1822 0.0003 0.3721

Caldwell 0.0003 0.0771 1.7803 0.0001 1.8579

Hays 0.0000 0.4081 0.0000 0.0006 0.4087

Travis 0.0000 2.5864 0.0143 0.0048 2.6055

Williamson 0.0000 0.7833 0.0265 0.0020 0.8117

TOTAL 0.0036 4.0413 2.0033 0.0079 6.0560

7 ftp://ftp.epa.gov/EmisInventory/2011v6/v3platform/reports/2011el_county_monthly_report.xlsx

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3 Implementation of Ozone Advance Program Action Plan and Other Measures

This section provides details on emission reduction measures implemented within the Austin-Round

Rock MSA in 2016. This includes both measures that had been included in the OAP Action Plan and other

measures that were not explicitly committed to in that plan.

3.1 Regional and State-Supported Measures Regional and state-supported measures involve multi-jurisdictional programs or state involvement in an

emission reduction measure within the region. These include:

The vehicle emissions inspection and maintenance (I/M) program

The Drive a Clean Machine program

Texas Emission Reduction Plan (TERP) grants

The Commute Solutions Program

The Clean Air Partners Program

The Clean Cities Program

Outreach and Education Measures

Property-Assessed Clean Energy (PACE)

CAPCOG’s Regional Air Quality Grants

3.1.1 Vehicle Emissions Inspection and Maintenance Program

The Austin-Round Rock MSA is home to Travis and Williamson Counties – the two largest “attainment”

counties in the Country that have a vehicle emissions inspection and maintenance (I/M) program. The

I/M program has been in place since September 1, 2005, and was implemented as part of the region’s

participation in the Early Action Compact (EAC) program. The program’s rules are found in Title 30, Part

1, Texas Administrative Code (TAC) Chapter 114, Subchapter C, Division 3: Early Action Compact

Counties. Under the program, all gasoline-powered vehicles (including heavy-duty vehicles but excluding

motorcycles) that are 2-24 years old are required to undergo an annual emissions inspection along with

their annual safety inspection. Vehicles model year 1995 and older are required to pass a “two-speed

idle” (TSI) test, and vehicles model year 1996 and newer are required to pass an “on-board diagnostic”

(OBD) test. The inspection costs $16 per test:

The station may retain $11.50

$4.50 is remitted to the state and deposited into the Clean Air Account (Fund 151):

o $2.50 is for state administration of the I/M program

o $2.00 is for the Low-Income Vehicle Repair, Assistance, Retrofit, and Accelerated Vehicle

Retirement Program (LIRAP)

If a vehicle fails an emissions inspection, the owner is required to fix the vehicle as a condition of

registration. As described in 37 TAC § 23.52(a), “an emissions testing waiver defers the need for full

compliance with vehicle emissions standards of the vehicle emissions inspection and maintenance (I/M)

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program for a specified period of time after a vehicle fails an emissions test.” The following waivers are

available in certain circumstances:

A “low-mileage” waiver if a motorist has paid at least $100 for emissions-related repairs and is

driven less than 5,000 per year

An “individual vehicle” waiver if a motorist has paid at least $600 in emissions-related repairs

Under 37 TAC § 23.53(a), time extensions are also available:

A “low-income time extension” is available if the motorist has income at or below the federal

poverty level and the motorist hadn’t previously received a time extension in the same cycle

A “parts-availability time extension” is available if an applicant can show problems in obtaining

the needed parts for repair

Based on research conducted by CAPCOG in 20158 and TCEQ’s most recent “trends” emissions

inventories,9 CAPCOG estimates that the emissions reductions from light-duty vehicles (vehicles with

gross vehicle weight ratings of <8,500 pounds) in the Austin-Round Rock MSA in 2016 were

approximately 2.27 tpd for NOX and 1.99 tpd for VOC across the two counties.

Table 3-1. Estimated 2016 NOX and VOC Emission Reductions from I/M Program for Light-Duty Vehicles (tpd)

Pollutant Travis Williamson Total

NOX 1.63 0.64 2.27

VOC 1.41 0.59 1.99

These estimates were based on empirically-based compliance factors in conjunction with the

MOVES2014 model. CAPCOG’s research found the following:

About 86.17% of vehicles in the Austin-Round Rock MSA that are required to get tested on-time

do so

Testing fraud impacts approximately 0.89% of vehicles subject to on-board diagnostic (OBD)

testing

The combined 85.19% “compliance rate” is lower than the 96% default compliance rate in

MOVES2014

The average waiver rate (the percentage of vehicles that failed a test but received a waiver) for

the region was 0.26% from September 2005 – December 2013, ranging from 0.21% - 0.30% in

any given year, significantly lower than the 3.00% default waiver rate in MOVES2014

8 Eastern Research Group. Inspection and Maintenance Program Benefits Analysis. Report Prepared for the Capital Area Council of Governments. September 21, 2015, revised December 16, 2015. Available online at: http://www.capcog.org/documents/airquality/reports/2015/Austin_Area_I-M_Benefit_Analysis_2015_revised_2015_12_16.pdf 9 Available online at: ftp://amdaftp.tceq.texas.gov/pub/EI/onroad/mvs14_trends/. Last Accessed 5/15/2017.

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The combined 85.19% “compliance factor” for light-duty gasoline-powered vehicles is lower

than the 93.12% default compliance factor in MOVES2014

The estimates do not account for the additional 0.20 – 0.67 tpd NOX emissions reductions and 0.12 –

0.25 tpd VOC emissions reductions from heavy-duty gasoline vehicles estimated by ERG in CAPCOG’s

2015 study for 2012 and 2018, respectively. Since MOVES2014 does not model emission reductions for

heavy-duty vehicles, these estimates are more uncertain than the emission reductions for light-duty

vehicles.

Some of the key metrics for I/M program year-to-year is the number of emissions inspections and the

failure rates. The following table summarizes the number and disposition of emissions inspections in

2016:

Table 3-2. I-M Program Statistics for 201610

Metric Travis County Williamson County Combined

Total Emission Tests 757,656 346,499 1,104,155

Initial Emission Tests 701,779 321,486 1,023,265

Initial Emission Test Failures 38,421 16,312 54,733

Initial Emission Test Failure Rate 5.5% 5.1% 5.3%

Initial Emission Retests 49,676 22,591 72,267

Initial Emission Retest Failures 4,945 1,934 6,879

Initial Emission Retest Failure Rate 10.0% 8.6% 9.5%

Other Emission Retests 6,201 2,422 8,623

Other Emission Retest Failures 1,706 647 2,353

Other Emission Retest Failure Rate 27.5% 26.7% 27.3%

In general, there have been year-over-year increases in the number of emissions inspections tracking

with population increases, except for 2015. The difference in 2015 was that, due to a transition period in

the state’s transition from a two-sticker (registration and inspection) system to a one-sticker system,

some vehicles were able to skip a cycle of inspections if they had a January 2015 or February 2015

registration renewal deadline. By March 1, 2016, however, all vehicles should have “caught up.”

10 Reports generated 3/28/2017

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Figure 3-1. Trend in Emissions Inspections Compared to Population in Travis and Williamson Counties 2006-2016

Despite the 1-year transition period in the inspection program in 2015, this did not halt the long-run

downward trend in the percentage of vehicles failing their initial tests.

Figure 3-2. Initial Emissions Inspection Failure Rate Trend 2006-2016

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

2,000,000

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Res

iden

t P

op

ula

tio

n

Emis

sio

ns

Insp

ecti

on

s

Emissions Inspections Population

0%

1%

2%

3%

4%

5%

6%

7%

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016

Initial Failure Rate

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The figure below shows the failure rate of each model year based on tests conducted in 2014, 2015, and

2016. As the figure below shows, the chances of older model-year vehicles failing an emissions test are

significantly higher than a newer model-year vehicle failing a test. For example, 2014 model year

vehicles had a failure rate of only about 2%, whereas model year 2001 vehicles had a failure rate of 14%,

7 times higher.

Figure 3-3. Failure Rate by Model Year

3.1.2 Drive a Clean Machine Program

The Drive a Clean Machine (DACM) program helps support the I/M program in Travis and Williamson

Counties by providing funding to moderate-income and low-income motorists for:

Repairing emissions control systems on vehicles that fail an emissions test;

Replacing a vehicle that fails an emissions test; and

Replacing a vehicle that is at least 10 years old.

Motorists can receive up to $600 for repairs, $3,000 for a car up to 3 years old, $3,000 for a truck up to 2

years old, or $3,500 for a hybrid or alternative-fueled vehicle up to 3 years old. New vehicles are

required to meet Tier 2 bin 5 or Tier 3 bin 160 or cleaner standard. Replacement vehicles cannot have an

odometer reading of more than 70,000 miles. Replacement vehicles can only be purchased through a

participating dealer and repairs must be performed by a recognized emissions repair facilities for Travis

and Williamson Counties.

0%

2%

4%

6%

8%

10%

12%

14%

16%

18%

2016 2015 2014

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There are 13 recognized repair facilities in Austin, 1 in Pflugerville, and 1 in Cedar Park11

There are 104 participating dealers in the Austin-Round Rock MSA12

The program achieves emission reductions beyond those that would be achieved by implementing an

I/M program without DACM in the following ways:

Increases program compliance by making it more likely that a motorist will bring in their vehicle

for a vehicle inspection based on the knowledge that financial assistance is available if they fail

the test

Increases program compliance by reducing low-income time extensions for repairs

Increases program compliance by replacing older vehicles more likely to fail an emissions test

with newer vehicles more likely to pass an emissions test

Accelerates the benefits of newer vehicle emissions standards by replacing older vehicles with

newer vehicles

In 2016, Travis County and Williamson County entered into an agreement to jointly administer their

DACM programs through Travis County in order to improve the program’s administrative efficiency.

Starting June 1, 2016, Travis County’s DACM staff began accepting applications from Williamson County

motorists. Data reported by Travis County for state fiscal year 2016 (September 1, 2015 – August 31,

2016) are shown below.

Table 3-3. DACM Program Data for State FY 2016

Item Travis County

Total Applications for Assistance 497

Number of Repair Vouchers Issued 172

Number of Replacement Vouchers Issued 179

Total Number of Vouchers Issued 351

Value of Repair Vouchers Issued $103,200

Value of Replacement Vouchers Issued $626,500

Total Value of Vouchers Issued $729,700

Number of Repair Vouchers Redeemed 125

Number of Replacement Vouchers Redeemed 106

Total Number of Vouchers Redeemed 231

Value of Repair Vouchers Redeemed $61,642

Value of Replacement Vouchers Redeemed $314,000

Total Value of Vouchers Redeemed $375,642

% of Applications Vouchers Issued For 71%

% of Repair Vouchers Redeemed 73%

% of Replacement Vouchers Redeemed 59%

% of Vouchers Redeemed 66%

% of Applications Ultimately Redeemed 46%

11 https://www.traviscountytx.gov/images/air_quality/docs/recognized_emission_repair.pdf, accessed 7/12/2017 12 https://www.traviscountytx.gov/images/air_quality/docs/AutoDealerList.xls, accessed 7/12/2017

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As the figure below shows, the number of vouchers redeemed declined from 2015 to 2016, continuing a

trend from 2014. The program was under-subscribed in 2016 as in prior years; Travis County used 35%

of the funding appropriated for vouchers in 2016.

Figure 3-4. DACM Repair and Replacement Voucher Trends 2009-2016

3.1.3 Texas Emission Reduction Plan Grants

Texas Emission Reduction Plan (TERP) grants provide funding for a variety of types of projects designed

to reduce emissions, particularly NOX. These include:

The Diesel Emissions Reduction Incentive (DERI) program, designed to achieve emission

reductions by incentivizing the early replacement or repowering of older diesel-powered

engines with newer engines

o The Emission Reduction Incentive Grant (ERIG) program is a competitive grant program

based on the cost/ton of NOX reduced

o The Rebate Grant program is a first-come, first-served grant program based on fixed

rebate dollar amounts based on fixed cost/ton of NOX reduced assumptions

The Texas Natural Gas Vehicle Grant Program (TNGVGP) incentivizes the replacement of diesel-

powered trucks with natural gas vehicle-powered trucks, with the newer engine needing to

achieve at least a 25% reduction in emissions compared to the diesel power it is replacing

The Texas Clean Fleet Program (TCFP) incentivizes owners of large fleets to replace a significant

portion of their conventionally-fueled vehicles with alternative-fueled vehicles, achieving

emission reductions by replacing the older, dirtier engines with newer, cleaner engines

The Clean School Bus (CSB) program provides funding for the installation of PM control devices

on older buses

0

100

200

300

400

500

600

700

800

Travis County RepairVouchers

Travis CountyReplacement Vouchers

Williamson County RepairVouchers

Williamson CountyReplacement Vouchers

2009 2010 2011 2012 2013 2014 2015 2016

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The Drayage Truck Incentive Program (DTIP) provides funding for the early replacement of

drayage trucks in port/intermodal facility areas

The New Technology Implementation Grants (NTIG) program provides funding for

new/innovative technology to reduce emissions from stationary sources

The Clean Transportation Triangle (CTT) provides funding for the construction of natural gas

fueling infrastructure in the region between Dallas-Fort Worth, San Antonio, and Houston in

order to encourage wider usage of natural gas-fueled vehicles

The Alternative Fueling Facilities Program (AFFP) provides funding for the construction of a

variety of types of alternative fuel infrastructure in nonattainment areas

The table below shows the TERP funding awarded to the Austin-Round Rock MSA in 2016, along with

any quantified NOX emissions reductions from those grants.

Table 3-4. TERP Grants Awarded in the Austin Area in 2016

Grant Program

Number of Grants Awarded

to the Austin Area

Funding Awarded to the Austin

Area

NOX Emissions Reductions from Grants Awarded

(tons)

NOX Emission Reductions from Grants Awarded

(tpd)

CTT13 3 $1,148,623 Unquantified n/a

CSB14 1 $407,487 Unquantified n/a

NTIG15 0 $0 N/A n/a

TCFP16 1 $1,070,220 11.03 0.0085

TNGVGP17 1 $210,000 7.71 0.0074

ERIG18 74 $7,647,598 817.89 0.4494

TOTAL 80 $10,483,928 836.63 0.4653

The following table shows the cumulative weekday NOX emission reductions projected for 2016-2019

from projects funded under the DERI, TCFP, and TNGVGP in the Austin area that were active as of

8/31/2016. Note that this projection does not account for any new grants awarded after 8/31/2016, and

the declines in emission reductions between 2017 and 2016 and between 2018 and 2017 reflect

projects that were funded years before that had reached their contract expiration dates.

13 https://www.tceq.texas.gov/assets/public/implementation/air/terp/reports/FY17/CTT_ActiveProjectList.pdf 14 https://www.tceq.texas.gov/assets/public/implementation/air/terp/clean_schoolbus/CSB_Active_Projects_for_WEB.pdf 15 https://www.tceq.texas.gov/assets/public/implementation/air/terp/ntig/Active_Projects_List_for_Website_minus_GC_083116.pdf 16 https://www.tceq.texas.gov/assets/public/implementation/air/terp/reports/FY17/TCFP_ActiveProjectList.pdf 17 https://www.tceq.texas.gov/assets/public/implementation/air/terp/reports/FY17/TNGVGP_ActiveProjectList.pdf 18 https://www.tceq.texas.gov/assets/public/implementation/air/terp/reports/FY17/DERI_ActiveProjectList.pdf

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Figure 3-5. Emission Reductions from TERP Grants Active as of 8/31/2016, 2016-2019

3.1.4 Commute Solutions Program

In 2016, the Capital Area Metropolitan Planning Organization (CAMPO) was not actively staffing the

Commute Solutions program, although it did continue to maintain the CommuteSolutions.com website

and the MyCommuteSolutions.com ride-sharing site. Towards the end of 2016, CAPCOG and other

stakeholders starting having discussions with CAMPO about possibly moving the program over to

CAPCOG. That process culminated in the transfer of the program in March 2017. Since the program was

not advertised or otherwise actively promoted in 2016, statistics for 2016 are significantly lower than

they were in prior years.

Table 3-5. MyCommuteSolutions.com Data for 2016

Mode/Type Entries Distance Miles Fuel Saved NOX Saved (lbs) VOC Saved (lbs)

Drove Alone 1,569 21,882 n/a n/a n/a

Carpool Driver 1,280 18,525 428 4.88 28.23

Carpool Passenger 819 12,023 246 3.52 16.19

Vanpool Driver 22 688 18 0.28 1.17

Vanpool Passenger 58 1,842 52 0.81 3.41

Bus 2,702 22,134 1,035 16.35 68.32

Rail 1,214 25,301 1,182 18.69 78.09

Bicycle 2,337 10,648 498 7.86 32.86

Walk 315 209 196 0.15 0.64

Telework 311 8,386 392 6.19 25.88

TOTAL 10,627 121,638 4,047 58.73 254.79

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The following organizations outside of the Clean Air Coalition have custom sub-sites for their

organizations:

Austin Community College

AMD

Applied Materials

BigCommerce

Dell

Downtown Austin Alliance

IBM

LDR Spine

NetSpend

Samsung Semiconductor

Texas State University

Texas Municipal Retirement System (TMRS)

W Austin Hotel

3.1.5 Clean Air Partners Program

CLEAN AIR Force’s Clean Air Partners Program includes reporting from a number of organizations

outside of the CAC. These include:

1. 3M

2. American Lung Association

3. Applies Materials

4. Austin Community College

5. Chemical Logic, Inc.

6. Emerson Process Management

7. EnviroMedia Social Marketing

8. Environmental Defense Fund

9. HNTB Corporation

10. Metropia

11. NXP

12. Oracle

13. Pfizer

14. R&R Limousine and Bus

15. Samsung Austin Semiconductor

16. Seton Healthcare Family

17. Spectrum

18. St. David’s Healthcare

19. TECO-Westinghouse

20. Tokyo Electron

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21. University of Texas at Austin

22. Zephyr Environmental Corporation

In addition, there are several CAC members who also participate in the Clean Air Partners Program:

1. CAPCOG

2. Central Texas Regional Mobility Authority (CTRMA)

3. Lone Star Clean Fuels Alliance (LSCFA)

4. Lower Colorado River Authority (LCRA)

5. TxDOT Headquarters

6. TxDOT Austin District

7. Williamson County

3.1.6 Outreach and Education Measures

With funding from City of Austin and the TCEQ air quality planning grant (Rider 7), CAPCOG completed a

number of outreach and education tasks in 2016, including:

Developing a new “Air Central Texas” outreach and education website

o ULR: www.AirCentralTexas.org;

o Created 56 pages with 16 total updates

o Spanish-language versions of all pages available

o An emissions impact calculator was created to help people understand the impact of

their day-to-day activities on regional ozone

o A total of 3,451 unique visitors through 11/30/2016

Conducting and coordinating regional in-person outreach and education;

o 29 events were staffed, with at least 3 in each county; up from 15 events in 2015

o 154.5 total staff hours at events, down from 168.5 in 2015

o 4,255 individuals contacted, up from 3,992 in 2015

o Average contact rate: 27.5 contacts/hour, up from 23.5 contacts/hour in 2015

Conducting electronic outreach and education;

o 2,077,166 total gross impressions19 (GIs) made at a cost of $18,050 ($8.70 per thousand)

o In 2015, CAPCOG spent $37,715 on radio ads from CAPCOG’s Inter-local Agreement (ILA)

with City of Austin, achieving 2,642,479 GIs ($13.44 per thousand)

Providing technical assistance to fleet managers for emission reduction grants;

o Contacted 23 organizations to provide technical assistance regarding applying for ERIG

grants

9 no response

7 no interest

2 possible interest (Georgetown and Hutto)

19 A “gross impression” is an instance in which 1 person sees or hears a message. The number of gross impressions is therefore equivalent to the number of persons who saw or heard a message times the average number of times they saw or heard the message.

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5 active interest (Austin White Lime, Texas Lehigh Cement Company, Caldwell

County, Travis County, and TxDOT)

Conduct targeted senior outreach to help reduce exposure on high air pollution days;

o 780 contacts with seniors using targeted outreach materials

o Leveraged existing contacts through CAPCOG’s Area Agency on Aging

Establish an “Air Central Texas” awards program

o Held an awards ceremony attended by 42 individuals on November 4, 2016

o Public Sector Award given to Williamson County Commissioner Ron Morrison

o Private/Non-Profit Sector Award given to the Lone Star Clean Fuels Alliance

o Bill Gill Central Texas Air Quality Leadership Award given to Tom “Smitty” Smith

CLEAN AIR Force’s (CAF) High School Public Service Announcement (PSA) contest received 6 entries from

5 high schools. Entries were due on January 31, 2016, with the winner selected in March 2016. Austin

Mayor Steve Adler made a proclamation for the winners on April 7, 2016. The first-place PSA ran from

April-May 2016.

City of Austin and CAF sponsored a Media & Meteorologist Lunch & Learn on August 5, 2016.

LSCFA sends out bi-monthly e-mail blasts and quarterly e-newsletters. They receive $45,000 per year

from the Department of Energy for specific deliverables, with additional funding coming from grants and

membership dues. LSCFA has 125 identified stakeholders in the region with 5 financially supporting

members. LSCFA events in 2016 included:

Propane in the Park – a propane mower event April 8 (75 attendees)

First responder training in use of alternative fueled vehicles August 17-18 (20 attendees)

Drive electric week promoting electric vehicles and hybrids (100 attendees)

CNG Tank Inspection Workshop for 1st-responders (40 attendees)

3.1.7 Property-Assessed Clean Energy (PACE) Program

The Property-Assessed Clean Energy (PACE) program provides an innovative mechanism for financing

renewable energy and energy-efficiency improvements to industrial, commercial, multi-family

residential, and non-profit buildings in participating jurisdictions. In order to address pay-back periods

for energy efficiency and renewable energy (EE/RE) projects that may not align properly with a private

property owner, the PACE program enables jurisdictions to put a property tax lien on a piece of property

where an EE/RE improvement is made using private financing until the loan for the project has been

paid back. PACE is authorized under state law in Section 399 of the Texas Local Government Code

Chapter 399.20 Projects include:

HVAC modification or replacement

Light fixture modifications such as LED

Solar panels

20 http://www.statutes.legis.state.tx.us/Docs/LG/htm/LG.399.htm

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High-efficiency windows or doors

Automated energy control systems

Insulation, caulking, weather-stripping or air sealing

Water-use efficiency improvements

Energy- or water-efficient manufacturing processes and/or equipment

Solar hot water

Gray water reuse

Rainwater collection systems

In 2016, both Travis and Williamson Counties participated in PACE. Travis County joined the PACE

program on March 24, 201521, and Williamson County joined on March 22, 201622. Hays County joined

on January 22, 2017.

The first PACE project in Texas was in Travis County and was announced on February 24, 2016 at Temple

Beth-Israel in Austin. The first solar PACE project in Texas was also in Travis County – a $262,000

investment at Family Eldercare in Travis County. On October 3, 2016, three projects in Travis and

Williamson Counties were initiated with Simon Property Group totaling $3 million in investments.

As of July 13, 2017 6 of the 9 completed PACE projects in the state were in Hays, Travis and Williamson

Counties.

Hays County:

o 1 project totaling $1,800,000 in investments

o 824,903 kWh in electricity consumption savings

o 3,139,000 gallons/year in water consumption savings

Travis County:

o 3 projects totaling $4,436,986 in investments

o 1,436,986 kWh/yr in electricity consumption savings

o 658,000 gallons/year in water consumption savings

Williamson County:

o 2 projects totaling $1,767,982

o 1,956,657 kWh/yr in electricity consumption savings

o 1,780,000 gallons/yr in water consumption savings

For more information on PACE, visit http://www.texaspaceauthority.org/.

21 https://www.traviscountytx.gov/images/commissioners_court/Doc/04-2015-resolution-pace.pdf 22 https://agenda.wilco.org/docs/2016/COM/20160308_1211/14757_2016%200227%20Williamson%20County%20Resolution%20of%20Intent%20%28030116%29.pdf

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3.1.8 CAPCOG Regional Air Quality Grants

CAPCOG received about $240,000 in air quality funding for the 2016-2017 biennium beyond what it had

initially sought and decided to use these funds to provide air quality grants within the region. Through

two rounds of grant applications, CAPCOG ultimately awarded five grants:

A grant to Austin Community College to help pay for the installation of solar panels on their

Highland Campus buildings

A grant to the City of Austin to support a pilot alternative commuting project at the City of

Austin for its employees

A grant to Travis County to incentivize the use of Capital Metropolitan Transit Authority

(CapMetro) vanpool services

A grant to Austin White Lime to replace several light-duty trucks used on the premises with

smaller, cleaner off-road vehicles to perform the same work

A grant to Austin White Lime to install an “electric ear” to improve the energy efficiency of one

of their kilns when burning coal

These projects had not yet been implemented as of the end of 2016, but are all in the process of being

completed as of the date of this report.

3.2 Organization-Specific Measures and Updates This section provides updates on measures implemented by CAC members. Supplemental electronic files

provide detailed, measure-by-measure, organization-by-organization details, while this section of the

report provides an overview of these measures, a. A stand-alone section for Texas Lehigh Cement

Company’s NOX emission reduction program is detailed here, as well as a note on Austin Energy’s

decision to postpone retirement of the Decker Creek Power Plant’s boilers 1 and 2. These measures are

based on reports collected from CAC members in May and June 2016. Organizations that did not report

as of the date of this report include:

City of Luling

City of Pflugerville

City of Taylor

Williamson County

CapMetro

If these organizations provide data subsequent to this report, CAPCOG will provide an updated version.

Many jurisdictions provided detailed operational data. CAPCOG intends to use this in a subsequent

technical report analyzing the emissions reduction impact of various OAP Action Plan measures.

3.2.1 Texas Lehigh Cement Company

The Texas Lehigh Cement Company in Buda (Hays County) voluntarily implements a NOX emission

reduction program on days when TCEQ forecasts “moderate” or higher ozone levels in the region. The

facility, which is the largest point source of NOX emissions within the Austin-Round Rock MSA, is

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equipped with a selective non-catalytic reduction (SNCR) system that it operates as needed to maintain

compliance with permit requirements. On days when TCEQ predicts that ozone levels in the region will

be “Moderate” or higher, Texas Lehigh will increase the NOX reduction efficiency of the system between

the key hours of 9 am – 3 pm, which prior modeling had shown were the most important hours for the

facility to reduce NOX emissions in order to reduce its contribution to high ozone levels within the

region.

In 2016, Texas Lehigh implemented this measure on 25 days, with an additional 20 days when it

intended to implement the measure but ultimately didn’t:

16 days when ozone levels were “moderate” or higher

o 37% of the days when ozone levels were “moderate” or higher

o 50% of the days that were in the top 4 for CAMS 3 and CAMS 38

o 15 days when O3 levels were forecast to be “moderate” or higher

o 1 day when O3 levels were forecast to be “good”

9 days when ozone levels were “good”

o 7 days when O3 levels were forecast to be “moderate” or higher

o 2 days when O3 levels were forecast to be “good”

5 days when there was a delayed start due to a late TCEQ forecast or other issues

10 days when Texas Lehigh intended to participate but couldn’t due to process issues

1 day not implemented due to operator error

2 days not implemented due to a change in TCEQ’s forecast

2 days not implemented due to other issues

Texas Lehigh noted the following days in their 2016 report.

Table 3-6. Days Texas Lehigh Highlighted on its 2016 Report

Date Note Most Recent O3

AQI Forecast Actual MSA Max MDA8 O3 (ppb)

Actual O3 AQI

3/14/2016 Participated Moderate 66 Moderate

3/15/2016 Late Start Moderate 49 Good

4/2/2016 Didn’t Participate Good 49 Good

4/3/2016 Didn’t Participate Good 54 Good

4/4/2016 Process Down Moderate 63 Moderate

4/5/2016 Process Down Moderate 61 Moderate

4/6/2016 Process Down Moderate 55 Moderate

4/7/2016 Process Down Moderate 62 Moderate

4/8/2016 Process Down Moderate 60 Moderate

4/15/2016 Process Down Moderate 49 Good

4/22/2016 Participated Moderate 59 Moderate

4/23/2016 Participated Unhealthy for

Sensitive Groups 69 Moderate

4/27/2016 Operator Forgot Moderate 62 Moderate

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Date Note Most Recent O3

AQI Forecast Actual MSA Max MDA8 O3 (ppb)

Actual O3 AQI

4/30/2016 Delayed Start Moderate 58 Moderate

5/4/2016 Participated Moderate 55 Moderate

5/5/2016 Participated Moderate 65 Moderate

5/6/2016 Process Issues Unhealthy for

Sensitive Groups 62 Moderate

5/13/2016 Participated Good 60 Moderate

5/14/2016 Process Issues Moderate 44 Good

6/6/2016 Process Issues Moderate 61 Moderate

6/7/2016 Participated Moderate 66 Moderate

6/8/2016 Participated Moderate 60 Moderate

6/9/2016 Participated Moderate 55 Moderate

6/19/2016 Participated Moderate 45 Good

6/29/2016 Process Issues Moderate 64 Moderate

6/30/2016 Participated Moderate 65 Moderate

7/1/2016 Participated Moderate 59 Moderate

7/22/2016 Participated Moderate 48 Good

8/8/2016 TCEQ Canceled Forecast Moderate 39 Good

9/1/2016 Participated Moderate 58 Moderate

9/2/2016 TCEQ Canceled Forecast Good 57 Moderate

9/4/2016 Participated Moderate 49 Good

9/12/2016 Participated Moderate 50 Good

9/20/2016 Late AQ Forecast from TCEQ Moderate 56 Moderate

9/21/2016 Participated Moderate 58 Moderate

9/22/2016 Participated Good 54 Good

9/28/2016 Participated Moderate 62 Moderate

9/29/2016 Participated Good 54 Good

10/3/2016 Process Issues Moderate 72 Unhealthy for

Sensitive Groups

10/9/2016 Participated Moderate 54 Good

10/10/2016 Participated Moderate 61 Moderate

10/11/2016 Participated Moderate 70 Moderate

10/28/2016 Participated Moderate 47 Good

11/16/2016 Late AQ Forecast from TCEQ Moderate 51 Good

11/17/2016 Late AQ Forecast from TCEQ Moderate 42 Good

Texas Lehigh also provided CAPCOG with hourly NOX emissions data for each of its two stacks: DC-2 and

DC-9. The figure below shows a comparison of the average hourly NOX emissions for each stack on days

when the NOX reduction measure was implemented versus when it was not. As the figure shows, on

days when the measure was implemented, NOX emissions are slightly higher between 12 am-9 am and 3

pm – 12 am on NOX reduction days than on normal days, but emissions much lower on days when the

measure was implemented.

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Figure 3-6. Texas Lehigh NOX Emissions by Hour on NOX Reduction Days and Regular Days, 2016

A 2015 report by CAPCOG showed that this measure could reduce peak 8-hour O3 concentrations at

regional ozone monitors by as much as 0.7-0.8 ppb in some locations.

Some other data reported by Texas Lehigh for 2016 includes the following:

Total 2016 Ozone-Forming Emissions Reported to TCEQ:

o NOX: 2,257 tpy, 12,705 pounds per ozone season day

o VOC: 189 tpy, 1,033 pounds per ozone season day

Total 2016 kiln fuel input:

o Coal: 3,572,551 MMBtu (63%)

o Petroleum Coke: 1,239,747 MMBtu (22%)

o Natural Gas: 832,142 MMBtu (15%)

Other Operational Data for 2016:

o 150 employees

o 66,043,000 CF natural gas consumed for non-kiln purposes

o 168,894 kWh electricity consumed

o 353,967 gallons of diesel consumed

o 4,846 gallons of gasoline consumed

o 22.2996 million gallons of water consumed

3.2.2 Austin Energy

Austin Energy’s decision in May 2016 to postpone the decommissioning of the Decker Creek Power

plant’s two boilers due to low natural gas prices was a setback for progress in reducing NOX emissions

0

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and ozone levels in the region. Based on an article in the Austin-American Statesman on May 26, 2016,

the utility now does not expect the replacement for Decker’s two boilers to be completed until 2022.23

3.2.3 Commuter Programs

CAC members implemented a number of commuter programs in 2016. These include:

Providing alternative commuting infrastructure (3 organizations)

Allowing employees to work compressed work weeks (4 organizations)

Allowing employees to work flexible work schedules (11 organizations)

Carpool or other alternative transportation programs (9 organizations)

Transit pass subsidized by employer (2 organizations)

Part-time teleworking (9 organizations)

Full-time teleworking (3 organizations)

Incentivizing alternative commuting among organization’s own employees (3 organizations)

Encouraging alternative commuting within the community (3 organizations)

3.2.4 Development Measures

Development measures implemented in 2016 included:

Access management: 3 organizations

Expedited permitting for mixed use, transit-oriented development, or in-fill development: 1

organization

Transit-oriented development: 2 organizations

Tree planting programs: 10 organizations

Tree maintenance programs: 9 organizations

Development policies to improve energy and resource efficiency in new buildings: 8

organizations

Codes and ordinances that encourage a more pedestrian-friendly environment: 5 organizations

3.2.5 Energy and Resource Conservation

Energy and Resource Conservation measures implemented in 2016 included:

Resource conservation: 7 organizations

Energy efficiency programs: 4 organizations

Renewable energy programs: 5 organizations

Electric vehicle programs: 1 organization

Water conservation programs: 7 organizations

Resource recovery and recycling programs: 7 organizations

23 http://www.mystatesman.com/news/local-govt--politics/austin-energy-hits-pause-plans-for-new-gas-plant-decker/bgRdQFZYtf2DOd2usGurcO/

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3.2.6 Fleet and Fuel Efficiency Measures

Fleet and Fuel Efficiency Measures included:

Alternative fuel vehicles: 4 organizations

Business evaluation of fleet usage, including operations and right-sizing: 7 organizations

Fueling of vehicles in the evening: 2 organizations

Low-emission vehicles: 4 organizations

Texas Low-Emission Diesel Equivalent for Fleets: 5 organizations

Vehicle maintenance by manufacturer specifications: 4 organizations

Prioritize purchasing of low-emission light-duty vehicles: 3 organizations

Prioritize purchasing of alternative-fueled vehicles and equipment: 2 organizations

Prioritize purchasing of hybrid vehicles: 2 organizations

Increase fuel efficiency: 3 organizations

Increase substitution of conventional fuels with alternative fuels: 2 organizations

Idling limits for vehicles and equipment: 7 organizations

Pursue replacement/repower/retrofit of old diesel-powered vehicles and equipment through

TERP and/or DERA funding: 5 organizations

Employee training on alternative fuels and fuel efficiency: 1 organization

3.2.7 Outreach and Awareness

Outreach and Awareness measures implemented by individual CAC members in 2016 included:

Employee education program: 7 organizations

Public education: 6 organizations

Ozone action day notification program: 9 organizations

Ozone action day response programs: 6 organizations

Programs to improve awareness of and compliance with air quality rules: 2 organizations

3.2.8 Regulation and Enforcement

Regulation and enforcement measures implemented by individual CAC members in 2016 included:

Open burning restrictions: 4 organizations

Special event emission reduction policies: 3 organizations

The following jurisdictions implement idling restrictions, either with a local ordinance, through a

memorandum of agreement (MOA) with TCEQ, or both.

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Table 3-7. Jurisdictions Implementing Idling Restrictions in the Austin-Round Rock MSA

Jurisdiction Local Ordinance TCEQ MOA

City of Austin ☒ ☒

City of Bastrop ☒ ☐

City of Elgin ☒ ☐

City of Georgetown ☒ ☒

City of Hutto ☒ ☐

City of Lockhart ☒ ☐

City of Round Rock ☒ ☐

City of San Marcos ☒ ☐

Bastrop County ☐ ☒

Travis County ☐ ☒

These idling restrictions are “passive’ controls in that the jurisdictions will respond to complaints when

they are made, but don’t devote dedicated resources to idling restriction enforcement. None of the

jurisdictions reported any citations being issued for idling in 2016.

3.2.9 Sustainable Procurement and Design

Sustainable procurement and design measures implemented by individual CAC members in 2016

included:

Direct deposit: 11 organizations

Restrictions on use of organization’s drive-through facilities on ozone action days: 2

organizations

E-government and/or remote locations: 6 organizations

Landscaping voluntary start at noon on ozone action days education program: 2 organizations

Low VOC asphalt: 1 organization

Low VOC roadway striping material: 2 organizations

Shaded parking: 3 organizations

Clean landscaping contracting: 3 organizations

Clean construction contracting: 3 organizations

Local sourcing of materials: 3 organizations

4 Ongoing Planning Activities This section documents notable air quality planning milestones and activities completed in 2016.

4.1 Clean Air Coalition Meetings

During 2016, there were a total of five Clean Air Coalition meetings, two of which were joint meetings

with AACOG’s AIR Executive Committee:

February 10, 2016

April 29, 2016 (joint meeting with AACOG)

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June 8, 2016

August 10, 2016

November 4, 2016 (joint meeting with AACOG)

Significant action taken by the CAC in 2016 included:

Updates to the CAC by-laws at the February meeting

Approval of a joint resolution on the Ozone NAAQS area designations and implementation at the

April meeting with AACOG

Approval of a comment letter to TCEQ regarding its 2016 annual monitoring plan at the June

meeting

Approval of a comment letter to EPA regarding its PM NAAQS review plan at the June meeting

Approval of Austin White Lime and City of Taylor as Clean Air Coalition members at the August

meeting

Approval of a joint resolution on 2017 air quality legislative priorities at the November meeting

with AACOG

The Clean Air Coalition Advisory Committee (CACAC) met five times:

January 7, 2016

February 4, 2016

May 12, 2016

July 14, 2016

October 13, 2016

The CACAC Outreach and Education Subcommittee bet a total of 7 times in 2016

April 21, 2016

May 11, 2016

June 1, 2016

August 3, 2016

September 7, 2016

October 5, 2016

November 2, 2016

The CACAC also established an idling workgroup that met four times in early 2016

January 27, 2016

February 24, 2016

March 30, 2016

April 28, 2016

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4.2 CLEAN AIR Force Meetings CLEAN AIR Force’s Board and Executive Committee met a number of times throughout the year.

Executive Committee Meetings:

January 25, 2016

February 3, 2016

September 20, 2016

September 28, 2016

November 2, 2016

December 7, 2016

Board Meetings:

February 3, 2016

November 2, 2016

Other special meetings & events included a field trip to Austin Water Utility’s Hornsby Bend facility, and

a December 7, 2016 meeting on potential LIP projects.

4.3 Regional Air Quality Technical Research Activities CAPCOG completed a number of air quality technical research activities in 2016 including:

Continued ozone and meteorological data collection at 8 CAPCOG-owned monitoring stations in

the region to supplement the 2 TCEQ ozone monitors in the region

Support for a new ozone monitor at St. Edward’s University (CAMS 1605)

Vertical measurement of ozone levels using balloons through a contract with St. Edward’s

University (St. Edward’s conducted a total of 16 launches)

An analysis of EPA’s 2014 National Emissions Inventory and development of updates for fuel

properties, inspection and maintenance compliance factors, and the area source commercial

fuel combustion categories based on local data

Development of a new ozone conceptual model for the region based on data collected between

2010 and 2015

Completion of a regional telephone survey of residents regarding air quality awareness and

issues

Reports and data from these projects can be found at http://www.capcog.org/divisions/regional-

services/aq-reports.

4.4 Statewide Collaborative Initiatives

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4.4.1 Regional Air Quality Planning Group

CAPCOG participated in meetings with the other 11 regional air quality planning groups across the state

on the following dates:

March 11, 2016

July 7, 2016

4.4.2 Texas Clean Air Working Group

CAPCOG participated in four Texas Clean Air Working Group (TCAWG) meetings in late 2016, as well as a

number of TCAWG subcommittees on TERP and Transboundary Air Pollution issues during this time.

September 15, 2016

October 20, 2016

November 9, 2016

December 15, 2016

5 Planning for the Future This section details some important issues to note for the region’s air quality plan moving forward,

including new issues that have arisen between the end of 2016 and the completion of this report. This

includes:

The implications of the Governor’s veto of funding for regional air quality planning, the DACM

program, and LIP program for FY 2018-2019

Changes to the TERP statute and TERP appropriations

The transfer of the Commute Solutions Program from CAMPO to CAPCOG

The EPA’s postponement of initial area designations for the 2015 Ozone NAAQS

Updates to the Region’s Advance Program Action Plan

5.1 Implications of Veto of Regional Air Quality Planning Funding On June 12, 2017, Governor Abbott line-item vetoed Rider 7 to TCEQ’s 2018-2019 budget, which was

the grant program that CAPCOG and a number of other “near-nonattainment areas” across the state

have relied on to fund regional air quality planning efforts for the past 20 years.24 This funding would

have provided $6 million out of the state’s Clean Air Account to fund planning efforts in the Austin,

Beaumont-Port Arthur, Corpus Christi, El Paso, Granbury, Killeen-Temple, San Antonio-New Braunfels,

Tyler-Longview-Marshall, Victoria, and Waco areas. CAPCOG had expected $1.26 million from this

funding for the biennium to fund planning activities for the Austin area. This grant had made up 76% of

the funding for CAPCOG’s air quality program between 2010 and 2017, including 94% of its staffing

costs.

Immediately following the veto, CAPCOG issued notices to its contractors to suspend uncompleted work

in order to preserve as much of CAPCOG’s funding from FY 2016-2017 as possible. CAPCOG will be able

to use the FY 2016-2017 funding out through June 30, 2018, but will need to rely on other sources of

24 https://gov.texas.gov/uploads/files/press/06122017_BudgetAndLineItemVetos.pdf

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funding beyond that. In absence of any new funding, CAPCOG would permanently shut down its ozone

monitors, reduce its staffing levels from 2.5 full-time equivalents (FTEs) to 1.5 FTEs on October 1, 2017,

and shut down the air quality program entirely after June 30, 2018.

At a June 28, 2017, emergency meeting of the CAC, CAPCOG explained the situation and laid out various

options for proceeding. The CAC unanimously endorsed a course of action that would involve CAPCOG

submitting funding requests totaling $287,000 to each of the jurisdictions in the CAC, with the request

to each jurisdiction based on population. The funding raised through these requests will be used in the

following priority order:

1. Resume air quality monitoring activities for the 2017 ozone season

2. Extend staffing for the air quality program at a 1.5 FTE level beyond June 30, 2018 to September

30, 2018 (the end of CAPCOG’s FY 2018 fiscal year)

3. Resume a limited monitoring program for the 2018 ozone season

4. Maintain staffing for the air quality program at 2.5 FTE through the end of September 30, 2018

5. Resume the full monitoring program for the 2018 ozone season

As of the date of this report, several jurisdictions had already approved funding in some fashion, while

others have scheduled consideration of this request at a City Council and County Commissioner Court

meeting. CAPCOG has asked for a response by July 24, 2017, and will proceed accordingly based on the

responses received by that date. Between August 2017 and March 2018, CAPCOG will work with the CAC

and other stakeholders to develop a longer-term strategy for funding the air quality program starting

October 1, 2018. The first opportunity for some kind of resumption of state funding would be

September 1, 2019.

5.2 Implications of Veto of Drive a Clean Machine and Local Initiative Project Funding In addition to the line-item veto of the Rider 7 air quality planning grants, Governor Abbott also line-

item vetoed Rider 24 to TCEQ’s FY 2018-2019 budget, which appropriated $97 million in funding out of

the state’s Clean Air Account for the state’s Low-Income Vehicle Repair Assistance, Retrofit, and

Accelerated Vehicle Retirement Program (LIRAP), also known as the “Drive a Clean Machine” or DACM

program, and Local Initiative Projects (LIP) program. Travis and Williamson Counties are currently

evaluating how to handle this development, but it appears that both counties are going to plan to

suspend terminate their collection of the $2 per inspection LIRAP surchargefee at some point after

September 1, 2017, while continuing to make any leftover money from LIRAP available out to August 31,

2019. The timing of when the fee suspension is important, since suspension prior to September 1, 2017,

would mean that the counties would not be able to continue administering the program with leftover

funding during the 2018-2019 biennium.

5.3 Texas Emission Reduction Plan

One of the more significant pieces of air quality-related legislation that passed during the 85th Texas

Legislative Session was Senate Bill (SB) 1731, which extended the TERP grant programs and made a

number of adjustments to the statutory authorizations for those programs found in Texas Health and

Safety Code (THSC). Some of the highlights of SB 1731 include the following:

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Extension of TERP grant programs until all areas of the state have been designated attainment

for all federal air quality standards

Re-establishes the Light-Duty Motor Vehicle Purchase or Lease Incentive Program, which had

expired at the end of FY 2015

Establishes a new Government Alternative Fleet Grant program

Expands the Drayage Truck Incentive Program to be a “Seaport and Rail Yard Areas Emission

Reduction Program” by adding cargo-handling equipment

Consolidates the Clean Transportation Triangle natural gas fueling infrastructure program with

the Alternative Fueling Facilities Program and adding counties in an area bounded by San

Antonio, Laredo, Corpus Christi, and Houston to the “Clean Transportation Zone” of eligible

counties

Allows repowers under the NGVGP and Drayage/Seaport program

Adds three new authorized uses of TERP funding:

o Research on the impact of foreign emissions and exceptional events

o Port studies

o A new government alternative fuel fleet grant program established under Chapter 395

Requires that TCEQ create a separate small business grant program or give preference to small

businesses in implementing the program, while also changing the definition of small businesses:

o Increases the maximum number of vehicles owned and operated from two to five

o Changes the requirement that the business own at least one on-road vehicle with a pre-

1994 engine or a non-road diesel piece of equipment with uncontrolled emissions, to

instead simply require that they own at least own and operate one on-road diesel

vehicle or one non-road diesel vehicle

Abolishes the TERP advisory board

Changes to the “Use of Fund” Section as outlined below

Table 5-1. Changes in TERP "Use of Fund" Restrictions for FY 2018-2019

Use of Fund Existing Citation

Existing Use Restriction

New Citation New Use

Restriction

CSB §386.252(a)(1) ≤ 4% No Change No Change

NTIG §386.252(a)(2) ≤ 3% No Change No Change

TCFP §386.252(a)(3) = 5% No Change ≤ 5%

N. Texas Air Toxics Monitoring

§386.252(a)(4) ≤ $3,000,000 No Change No Change

NGVGP (§386.252(a)(5)) §386.252(a)(5) ≥ 16% No Change ≤ 10%

CTT §386.252(a)(6) ≤ 5% Eliminated Eliminated

AFFP §386.252(a)(7) ≤ 5% §386.252(a)(6) ≤ $6,000,000,

none for FY 2019

Air Quality Research §386.252(a)(8) Specified Amount

§386.252(a)(7) ≤ $750,000

Health Effects Study §386.252(a)(9) ≤ $200,000 §386.252(a)(8) No Change

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Use of Fund Existing Citation

Existing Use Restriction

New Citation New Use

Restriction

Transfer into Clean Air Account for Planning in

Affected Counties §386.252(a)(10) = $500,000 §386.252(d) No Change

TCEQ Administration §386.252(a)(11)

= 4%, with minimum of

$4,000,000 and maximum of $7,000,000

§386.252(a)(9)) $6,000,000 to

$8,000,000

Drayage Truck Incentive Program/Seaport and

Rail Yard Areas Emission Reduction Incentive

Program

§386.252(a)(12) 2-5% §386.252(a)(10) ≤ 6%

Light Duty Motor Vehicle Purchase or Lease Incentive Program

§386.252(a)(13) ≤ 5%25 §386.252(a)(11) No Change

TEES Contract to Quantify Emission

Reductions §386.252(a)(14) $216,000 §386.252(a)(12) No Change

TEES Administrative Costs

§386.252(a)(15) = 1.5% §386.252(e) As may be

appropriated

DERI §386.252(a)(16) Remaining §386.252(a)(14) No Change

Other programs26 §386.252(f) As may be

appropriated §386.252(b) No Change

Port Studies n/a n/a §386.252(a)(13) ≤ $500,000

Foreign Emissions and Exceptional Events

Research n/a n/a §386.252(f)

Up to $2,500,000 to the extent that

money is appropriated for

this purpose

Government Alternative Fuel Grant Program

n/a n/a §386.252(g)

Up to 3% of the TERP fund

balance to the extent money is appropriated for

this purpose

25 This program had expired on August 31, 2015, although the language related to this “use of fund” had not. 26 Encompasses three citations: §386.051(13), §386.051(14), and §386.051(b-1). These include “other programs the commission may develop that lead to reduced emissions of nitrogen oxides, particulate matter, or volatile organic compounds in a nonattainment area or affected county,” “other programs the commission may develop that support congestion mitigation to reduce mobile source ozone precursor emissions,” and other programs to reduce emissions, prevent areas of the state from being in violation of NAAQS, reducing emissions from school buses, and advancing new technologies that reduce emissions from stationary sources.

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Under the appropriations bill SB1, the Legislature appropriated a total of $77,369,870 per year,

$154,739,740 for the biennium, to TERP for FY 2018-2019, down 35% from the $236,263,007

appropriated for FY 2016-2017 and Although Rider 24 to TCEQ’s budget provides an estimate of the

allocation of the funding, based on the existing statutory language present for FY 2016-2019, it does not

actually specify the amounts expected to be made available for each program.

Under the TERP statute, §386.252(c) (formerly (g)) “If the Legislature does not specify amounts or

percentages from the total appropriation to the commission to be allocated under Subsection (a) or (b),

the commission shall determine the amounts of the total appropriation to be allocated under each of

those subsections, such that the total appropriation is expended while maximizing emission reductions.”

Based on the cost-effectiveness of the DERI program compared to all of the other grant programs, this

language would seem to suggest that TCEQ would be obligated to allocate as much funding as possible

to the DERI program, even if it meant eliminating funding for some of the authorized uses entirely.

Traditionally though, in the face of similar language in the appropriation bills, TCEQ has simply allocated

the amounts that correspond with some limit described in the TERP statute, whether it was a maximum

or minimum. If this were the case in the coming biennium, TCEQ would allocate the maximum 3%

allowable allocation for the Clean School Bus program and the minimum 16% allowable allocation for

the Natural Gas Vehicle Grant Program. The air quality research allocation traditionally has been $1

million per year, despite lack of specific direction in statute or in the appropriations bills. After all of

these allocations were accounted for, TCEQ would then use the remaining balance for the DERI

program. CAPCOG has no knowledge or understanding of how TCEQ will actually allocate TERP funding

in the coming biennium.

The table below shows the estimated allocation each program would receive based on: 1) a scenario in

which TCEQ allocated the maximum amount of funding allowable to each use of fund for which a

specific statutory restriction exists in 386.252(a), and 2) a scenario in which TCEQ allocated the

maximum amount of funding allowable to the most cost-effective program (DERI). This illustrates two

ends of the spectrum of possibilities for how the funding could be initially allocated.

Table 5-2. Alternative Allocation Scenarios for FY 2018-2019 TERP Funding

Program

Each Program Allocated Maximum

Described in §386.252(a)

Estimated NOX Reductions from

Allocating Maximum

Described in §386.252(a)

Allocation to Maximize NOX

Reductions

Estimated NOX Reductions

from Allocating to

Maximize NOX Reductions

Clean School Bus $6,189,589 28127 $0 0

NTIG $4,642,192 028 $0 0

27 CSB cost/ton estimated to be $22K per ton based on table 7 from EDF report on federal clean school bus program: https://www.edf.org/sites/default/files/cleanbuses_14_screen.pdf. 28 NTIG: there are no reports on TCEQ’s website accounting for the NOX reductions from this program

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Program

Each Program Allocated Maximum

Described in §386.252(a)

Estimated NOX Reductions from

Allocating Maximum

Described in §386.252(a)

Allocation to Maximize NOX

Reductions

Estimated NOX Reductions

from Allocating to

Maximize NOX Reductions

TCFP $7,736,987 9929 $0 0

N. Texas Air Toxics Monitoring

$6,000,000 0 $0 0

NGVGP $15,473,974 55330 $0 0

AFFP $6,000,000 0 $0 0

Research $1,500,000 0 $0 0

Health Effects Study

$400,000 0 $0 0

Administration $8,000,000 0 $6,000,000 0

Drayage/Ports $9,284,384 54631 $0 0

Light Duty Program

$7,736,987 832 $0 0

ESL Contract $432,000 0 $0 0

Port Studies $500,000 0 $0 0

DERI $72,343,624 7,23433 $142,739,737 14,274

TOTAL $154,739,737 8,721 $154,739,737 14,274

This suggests that TCEQ could achieve 64% more NOX reductions if it allocated all of the funds to the

DERI program except the minimum $6 million/year required for administration beyond the emission

reductions that could be counted on if TCEQ allocated the maximum allowable funding to each of the

other programs.

In reality, though, the DERI, TCFP, and NTIG programs have been over-subscribed, while the other

programs have tended to be under-subscribed. The following table shows the most recent account TCEQ

has provided to CAPCOG of the “demand” for each grant round during the 2016-2017 biennium.

29 TCFP: cost/ton estimated to be $78K per ton ratio from all projects funded through 8/31/2016: https://www.tceq.texas.gov/assets/public/implementation/air/terp/reports/FY17/TCFP%20Projects%20by%20Area%20and%20Fuel%20Type.pdf 30 NGVGP: cost/ton estimated to be $28,000 based on all projects funded through 8/31/2016: https://www.tceq.texas.gov/assets/public/implementation/air/terp/reports/FY17/TNGVGP%20by%20Area%20and%20Fuel%20Type.pdf 31 Drayage/Ports: cost/ton estimated to be $17,000 based on all projects funded through 8/31/2016: https://www.tceq.texas.gov/assets/public/comm_exec/pubs/sfr/079-16.pdf (appendix 11) 32 Light Duty: based on $1 million/ton figure cited by NCTCOG at a TCAWG meeting 33 DERI Based on $10K per ton ratio; slightly higher than the average ratio from the most recent ERIG grant round for FY 17

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Table 5-3. TERP Grant Demand Summary as of April 21, 2017

Program Period Initial

Allocation Revised

Allocation Grant

Applications Awarded

DERI-ERIG FY 2016 Remaining $61,573,092 $64,250,080 $50,478,325

DERI-ERIG FY 2017 Remaining $51,741,371 $140,676,284 Pending

DERI-Rebate FY 2016 Remaining $0 n/a n/a

DERI-Rebate FY 2017 Remaining $10,000,000 $13,012,274 $11,833,188

Drayage Trucks

FY 2016-2017

$4,725,260 $4,725,260 $1,351,805 $911,936

TCFP FY 2016 $5,906,908 $7,402,663 $37,962,808 $7,402,663

TCFP FY 2017 $5,906,908 $22,488,990 $30,981,608 $21,026,614

TNGVGP FY 2016-

2017 $37,802,081 $37,802,081 $5,602,500 $3,759,000

CTT/AFFP FY 2016 $11,812,424 $11,812,484 $8,497,573 $5,879,623

CTT/AFFP FY 2017 $11,813,816 $17,720,377 $5,308,893 $4,176,888

CSB FY 2016 $4,724,994 $4,724,994 $3,667,340 $2,247,218

CSB FY 2017 $4,725,527 $6,554,330 $3,104,370 $1,545,545

NTIG FY 2016 $3,543,745 $3,543,745 $7,274,169 $3,543,745

NTIG FY 2017 $3,544,145 $3,544,145 $15,869,959 $3,544,145

Subsequent reports from TCEQ on awards granted indicate show:

$58,884,422.22 was ultimately awarded for FY 2017 ERIG grants, achieving an estimated 6,339

tons of NOX reductions34; and

$6,162,750 was ultimately awarded for the TNGVGP35.

Final amounts awarded for DTIP and rebate grants have not been announced yet.

TCEQ’s TERP reports to the 84th and 85th Texas Legislatures also indicate that the North Texas Air

Monitoring program used an average of $1.3 million/year, $1.7 million less money than the $3

million/year that it has been allocated, and that this $1.7 million/year extra is allocated to DERI.

To the extent that there is unused money in other programs after a grant solicitation and the TCEQ had

the authority to re-allocate the funding, it typically would redirect funding unused funding into the DERI

program. However, that does not change the extent to which any funding awarded under these other

programs may be achieving fewer emission reductions than what could be achieved by allocating the

maximum available into the DERI program. CAPCOG estimates that, after funding re-allocations

(assuming any surplus funding were to be allocated to the DERI program ), the total amount of

34 https://www.tceq.texas.gov/assets/public/implementation/air/terp/FY17_ERIG_Applications_Selected_For_Funding_FOR_WEB.pdf 35 https://www.tceq.texas.gov/assets/public/implementation/air/terp/FY17_TNGVGP_Applications_Selected_For_Funding_FOR_WEB.pdf

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quantified NOX reductions from FY 2018-2019 would be 9,552 tons of NOX, 33% lower than what could

be achieved by allocating the maximum amount of funding allowable to the DERI program.

It is not yet clear what approach to the initial allocations or subsequent re-allocation of funding TCEQ

may take, although CAPCOG believes that the language in 386.252(c) strongly suggests that TCEQ would

be obligated to demonstrate how allocating the maximum allowable to each grant program would other

than DERI would be expected to achieve a higher level of emission reductions than allocating the

maximum amount of funding to DERI if that is the path they chose.

Based on CAPCOG’s analysis of the allowable uses of the fund for analyzing foreign emissions and the

alternative fuel fleet grant program in §386.252(f) and (g) in the new statute and CAPCOG’s analysis of

the appropriations bill, CAPCOG believes that it is unlikely that TCEQ will interpret the Legislature as

having authorized any expenditures for those two purposes, particularly since a contingency rider in the

Senate version of the appropriations bill that would have provided that funding did not make it into the

final version of the appropriations bill signed into law. Some reports on SB 1731 suggest that these two

funding amounts could only come out of “the corpus” of the TERP fund balance, although the actual

statutory language contains no such restriction. The Comptroller’s 2018-2019 revenue estimate projects

a $1.384 billion fund balance for TERP at the end of FY 2017 and, based on the final appropriations bill,

this balance would rise to $1.522 billion at the end of FY 2018 and $1.670 billion at the end of FY 2019.

This means that the Government Alternative Fuel Grant Program could receive as much as $50 million

per year for FY 2020 and 2021. Due to some of the Legislature’s budgetary practices, however, it is likely

that any appropriation to this program would wind up reducing the amount available to the DERI

program.

General Revenue-Dedicated fund balances, including TERP, are used by the Texas Legislature and the

State Comptroller to certify budgets. The Comptroller includes any fund balances as of the start of a

biennium as funding available for appropriation in that biennium. Since any spending from these funds

in excess of the revenue deposited into them would require spending reductions or revenue increases

elsewhere in the budget, these general revenue-dedicated funds are functionally treated as unrestricted

for the purpose of certifying that the budget balances, even though they can only be used for the TERP

programs. Therefore, any appropriation of TERP funding to the government alternative fuel grant

program or the foreign emissions and exceptional events analysis would necessitate an equivalent cut

elsewhere in the budget or an overall increase in state revenue. As a result, the TERP account continues

to grow since less money is appropriated than is collected. Without a significant change in the way this

budgetary issue is handles, it seems likely that TERP will continue to receive significantly less in

appropriations than is collected in revenue, and the fund balance will continue to increase, limiting the

emission reductions that could be achieved through these programs.

Two other items of note:

If EPA decides to rescind or back-track on the 2015 Ozone NAAQS and instead just continue

implementing the 2008 Ozone NAAQS, as apparently they are considering at the moment, this

could move up the expiration of the TERP program to a significantly earlier date, as only the

Dallas-Fort Worth and Houston areas have ozone levels that exceed the 2008 ozone NAAQS. In

2023 ozone modeling released by EPA on January 25, 2017, it showed that both areas would be

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expected to have attained the 2008 NAAQS by 2023, but would still have design values of 74

ppb and 73 ppb, respectively.36

While SB 1731 did extend the authorization for expenditures on TERP grants, it did not extend

the revenue authorizations, which are set to expire on August 31, 2019. If this revenue is not re-

authorized, it could pose significant problems for appropriating funding out of the FY 2020-2021

budgets and beyond for TERP grants.

5.4 Commute Solutions Program

In early 2017, CAPCOG convened a meeting of stakeholders interested in the Commute Solutions

program to try to determine the future of the program, since it had not been actively managed by

CAMPO since the summer of 2015. At that meeting, the organizations present, including CAMPO,

CapMetro, CTRMA, City of Austin, and Travis County, agreed to work towards moving the program to

CAPCOG and establishing a steering committee of organizations to help guide the program moving

forward. On March 8, 2017, CAMPO and CAPCOG executed an interlocal agreement formally

transferring the Commute Solutions program to CAPCOG. CAPCOG has since taken over operational

control of the program, including management of the CommuteSolutions.com website and

MyCommuteSolutions.com ride-sharing/trip-planning platform. CAPCOG has continued to convene

steering committee meetings for the program and has started to raise money for the program, sponsor

electronic advertising, purchase incentives for users of the MyCommuteSolutions.com platform to use

the platform, and re-establish relationships with organizations that previously participated in the

program. CAPCOG will be developing a business plan for the program and expects that to be completed

in late 2017.

5.5 Postponement of Area Designations for 2015 Ozone NAAQS

EPA’s announcement on June 6, 2017, that the Administrator had decided to extend the initial area

designations for the 2015 Ozone NAAQS injected some new uncertainty into the Austin area’s air quality

planning process. The Austin area’s 2014-2016 design value of 66 ppb was below the 2015 Ozone

NAAQS and presumably would have been the basis of EPA’s designation if it had proceeded with its

initial plan to complete designations by October 1, 2017. However, midway through the 2017 ozone

season, the Austin area’s design value has now climbed to 68 ppb, While 2015 had higher-than expected

ozone concentrations, based on modeling data, the long-term trends in ozone concentrations, and the

typical year-to-year variability on ozone concentrations, 2014 and 2016 had lower-than expected ozone

levels.

As a result, the 2014-2016 66 ppb average was lower than what one might have expected for the region.

While the first half of the 2017 ozone season has resulted in an increase in the three-year average by 2

ppb, it is unlikely that the Austin area will wind up with a 2015-2017 design value of 71 ppb or higher.

That would require an MDA8 value of 76 ppb at CAMS 3, which hasn’t been reached since 2009, or 78

36 https://www.epa.gov/airmarkets/notice-data-availability-preliminary-interstate-ozone-transport-modeling-data-2015-ozone

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ppb at CAMS 38, which hasn’t been reached since 2006. However, CAPCOG will continue to monitor the

situation as it proceeds.

5.6 Updates to the Region’s Advance Program Action Plan The Austin-Round Rock MSA’s Advance Program Action Plan is set to expire on December 31, 2018.

While the Clean Air Coalition has expanded since the adoption of the action plan, the EPA’s decision to

set the 2015 Ozone NAAQS at 70 ppb, combined with the status of the region’s air pollution levels and

the Governor’s veto of funding for the air quality planning and DACM programs creates a very different

set of circumstances than what the CAC faced in 2013 when the current plan was adopted. CAPCOG

believes that the CAC will wish to have a new Action Plan adopted at some point in 2018, but it is

uncertain what that might look like in light of these uncertainties. Some key questions that CAPCOG

believes will need to be addressed in the process of creating a new plan to cover 2019-2023 include:

Whether the plan should address only ozone or be a multi-pollutant plan?

Whether Travis and Williamson Counties will continue to want to implement a vehicle emissions

inspection and maintenance program in light of the elimination of the DACM program as a way

to mitigate the financial burden of the I/M program on low- and moderate-income residents?

Which organizations are not in the Clean Air Coalition that should be?

Which of the measures in the current plan are high-value and warrant careful tracking, analysis,

and reporting, versus ones that are not?

Are there measures not in the current plan that should be?

What types of ongoing air quality planning, outreach and education, and technical research

work should be conducting conducted by CAPCOG or others to support the regional air quality

plan?

How should a regional air quality plan be funded starting with FY 2019?

CAPCOG will keep EPA and TCEQ informed of progress in the development of a new Action plan as we

start to tackle these questions with the CAC.

6 Conclusion In 2016, the Austin-Round Rock MSA continues to make progress on air quality, although cuts to TERP

funding and the Governor’s veto of funding for regional air quality planning, the DACM program, and the

LIP program in 2017 pose significant challenges to the region’s air quality planning efforts. As reported in

mid-201637 and in CAPCOG’s 2015 air quality report,38 Austin Energy’s decision to postpone retirement

of the Decker Creek power plant also delays the significant emission reductions that this development

37 Hicks, Nolan. “Austin Energy hits pause on plans for a new gas plant at Decker.” Austin-American Statement. May 24, 2016. Available online at: http://www.mystatesman.com/news/local-govt--politics/austin-energy-hits-pause-plans-for-new-gas-plant-decker/bgRdQFZYtf2DOd2usGurcO/. 38 http://www.capcog.org/documents/airquality/reports/2016/Deliverable_1.1.1-2015_Air_Quality_Report_for_the_Austin-Round_Rock_MSA.pdf

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would be expected to achieve39. As one of the largest sources of NOX reductions in the Austin-Round

Rock MSA (see section 3.1.3 of this report), and based on the impact of NOX emissions relative to VOC

emissions in the region (see section 2.1 of this report) and the narrow margins by which the region has

been able to remain in compliance with the ozone NAAQS over the past several years, TERP grants have

been critical to the region’s success at maintaining compliance with the NAAQS. The funding cuts for

TERP are likely to slow the progress the region has been making in reducing emissions.

39 See CAPCOG’s 2015 report page 79 for more details on the emission reductions expected.